Method for distribution of a drug

ABSTRACT

A method of providing an anti-VLA-4 antibody to a patient.

The application claims priority to U.S. Provisional Application No.60/836,530, filed Aug. 9, 2006, which is hereby incorporated byreference.

BACKGROUND

The invention relates generally to methods and systems for drugdistribution.

SUMMARY

The invention features methods and systems for distributing or providinga therapy, e.g., a drug. The drug can be a VLA-4 blocking agent, e.g.,an anti-VLA-4 antibody, e.g., TYSABRI® (natalizumab) or an equivalent orsimilar antibody. Methods and systems of the invention are particularlyuseful for drugs which may weaken the immune system. The drug can beadministered to treat a patient for a disorder mediated by VLA-4. Thedrug can be used to treat a patient having multiple sclerosis (MS),Crohn's disease, or a fibrotic condition. In a preferred embodiment thepatient has relapsing MS. Methods and systems can include one or more ofthe steps or elements described herein.

Accordingly, in one aspect, the invention features, a method or systemfor providing a drug, e.g., an anti-VLA-4 antibody, to a patient, e.g.,an MS patient. The system or method includes:

(1) collecting patient and prescriber information, e.g., by providing anenrollment form which includes patient and prescriber information to acentral administrator;

(2) reviewing the information, e.g., reviewing an enrollment form whichincludes the information, entering the information into a system (e.g.,a computerized system of one or more computers which can store data,allow data to be retrieved, generate reminders, transmit information andthe like), and generating an authorization for treatment of the patient;

(3) communicating the authorization to a treatment site;

(4) conducting (or instructing or authorizing a party to conduct) atreatment site review of a patient which includes gathering medicalinformation about the patient which information is needed to allowadministration of the drug, wherein said review can include one or moreof:

-   -   i. determining if the treatment site has a current authorization        for treatment of the patient;    -   ii. confirming that the treatment site does not have notice that        the patient is no longer authorized    -   iii. providing the patient with information about the drug;    -   iv. asking the patient if symptoms have worsened;    -   v. asking the patient if he/she has a contraindicated medical        condition;    -   vi. asking the patient if he/she has taken a contraindicated        medication; wherein an answer of no to iv, v, and vi (or a        preselected subset thereof) allows administration of the drug to        the patient and an answer of yes to one or more of iv, v, or vi        requires the prescriber (or the prescriber's designee) override        in order for the drug to be administered; and optionally

(5) upon expiration of an authorization obtaining reauthorization forsubsequent treatment prior to subsequent treatment, whereinreauthorization can require certification by a prescriber that thesubject is qualified to be in the program, e.g., by updating some or allof the information gathered in step 1, or by a prescriber certifying oneor more of the following:

-   -   (a) the patient still under his/her care;    -   (b) the patient is alive;    -   (c) the patient has had no unwanted side effect of the drug, no        contraindicated condition, or no contraindicated treatment that        the prescriber has not already reported to the central        administrator,

provided that if the prescriber reauthorizes the patient must stillundergo the review in step (4) prior to receiving the drug.

In a preferred embodiment authorization is necessary but not sufficientfor allowing administration of the drug. In a preferred embodimentauthorization and satisfaction of treatment site review are sufficientfor administration. In a preferred embodiment authorization andsatisfaction of treatment site review are necessary but not sufficientfor administration.

In a preferred embodiment each shipment of the drug requires that adistributor of the drug obtains a shipment authorization from thecentral administrator.

In a preferred embodiment the drug is shipped only to and administeredonly at authorized treatment sites.

In a preferred embodiment central pharmacies that dispense the drug toauthorized treatment sites are enrolled in a tracking system.

In a preferred embodiment the central administrator systematicallyfollows and actively solicits information on every patient that receivesthe drug regarding any adverse events.

In a preferred embodiment a system described herein includes: a userinterface for inputting a query; and a processor for generating a queryresult.

In a preferred embodiment the method or system is applied to at least50, 100, 500, 1,000, or 10,000 patients.

The invention includes computers, databases, and communication modulesconfigured to implement the methods described herein.

In another aspect, the invention features a method or system forproviding a drug, e.g., an anti-VLA-4 antibody to a patient, e.g., an MSpatient. The method or system includes one or more of the followingsteps or elements:

(1) Enrollment of the patient and, optionally, the prescriber in thesystem. In a preferred embodiment, once the decision to prescribe ismade, the prescriber and the patient complete and, optionally, sign oracknowledge, an enrollment form (forms, checklists and other documentsreferred to herein can individually or collectively be any ofelectronic, digital, or tangible, e.g., paper). The completed enrollmentform is sent to the central administrator.

(2) Review of the enrollment information. The central administratorreviews the completed enrollment form, enters the information from theform into the system (e.g., into a computerized data base and generatesan “authorization.” The authorization or approval can be, e.g., anelectronic or paper “form”, e.g., an authorization form.

(3) Communicate information to the treatment center. The authorization,and optionally other information, e.g., from the authorization formgenerated in (2), is communicated to the treatment site, e.g., aninfusion site (as described herein) and to the prescriber, e.g., bysending the authorization form to both by, e.g., facsimile.

(4) Treatment site processing. When the patient arrives at the treatmentsite, e.g., infusion site, a review is conducted. Indication of theauthorization, e.g., an authorization form generated in (2), isnecessary but not sufficient to allow treatment. In addition toconfirming possession of a current authorization, the treatment sitecarries out a specific or preselected procedure, in which the patient isscreened for eligibility to receive the drug. Thus, in addition tohaving a current authorization for treatment, a number of issues areresolved before the treatment site can treat the patient. An exemplarytreatment site review is as follows:

Before the treatment site can administer the drug, it must check to seeif the patient is currently authorized to receive the drug. This can bedone by the treatment site referring to the patient's medical record andcompleting one or more, and preferably all of, the following steps:

(a) If the patient did not receive his or her previous infusion, andphysician clearance was required, the treatment site must confirmauthorization from the prescriber before providing the currenttreatment;

(b) Confirm that the treatment site has a current “authorization” onfile (if the information, e.g., an authorization form, has been lost,the treatment site can contact the central administer for a replacementform);

(c) Confirm that the treatment site does not have a notice that thepatient is no longer authorized, e.g., a Notice of Discontinuation(described herein) or similar form, on file;

(d) Provide the patient with information about the drug, e.g., provide acopy of a Patient Medication Guide (described herein) or a similar guideor information;

(e) An investigation of one or more predetermined matters must be madebefore treatment. These can include one or more of the followinginquiries:

-   -   (i) Has the patient had worsening symptoms?    -   (ii) Does the patient have a contraindicated medical condition,        e.g., one that can weaken the immune system? Examples are HIV        infection or AIDS, leukemia or lymphoma, or an organ transplant.    -   (iii) Has the patient taken a contraindicated medication?        If the patient answers “no” to a predetermined set of these        inquiries, e.g., “no” to all of them, treatment can proceed. If        the patient answers “yes” (or does not know the answer) to a        preselected set, e.g., any one of these inquiries, the patient        cannot be treated without override by the prescriber (or the        prescriber's designee). In this case, the prescriber must be        contacted for further instructions. After the treatment site        discusses the findings with the patient's prescriber, the        prescriber can override and verbally instruct the treatment site        to treat the patient.

In a preferred embodiment, the treatment site is required to send thecentral administrator notice that the procedure was complied with. E.g.,any authorization by the prescriber must be documented.

In a preferred embodiment, step (4) includes substeps (b) and (e).

(5) Reauthorization for treatment. The authorization lasts for a maximumof a preselected period. At preselected intervals, the centraladministrator will send the prescriber a status form, e.g., a PatientStatus Report and Reauthorization Questionnaire described herein, or asimilar form. This form must be completed and entered into the systemfor further treatment to occur. Exemplary questions on the status formcan include, e.g., one or more of:

-   -   (a) Is the patient still under your care?    -   (b) Is the patient alive?    -   (c) Does the patient have an unwanted side effect of the drug, a        contraindicated condition, or a contraindicated treatment that        you have not already reported to the central administrator?        The prescriber must provide answers to these questions and        recommend reauthorization for the treatment to continue. If        reauthorization is given, the patient would then show up at the        treatment site for his/her next treatment and be put through the        Treatment Site Processing described in step (4) above.

(6) Controlled distribution system of the drug. Prior to each shipmentof the drug, a distributor obtains a shipment authorization from thecentral administrator. The drug is shipped only to authorized treatmentsites, e.g., infusion sites, designated by the central administrator.

(7) Training of treatment sites. The drug is shipped only to andadministered only at authorized treatment sites, e.g., infusion sites.Authorized treatment sites are sites that have been trained by thecentral administrator, e.g., employees of the central administrator, onthe known risks, potential benefits and appropriate use of the drug,using educational materials. The treatment sites must agree to complywith, e.g., one or more other requirements described herein. Forexample, before treatment, the treatment site will complete a checklist,e.g., a pre-treatment checklist described herein, and return thecompleted checklist to the central administrator, e.g., by mail,facsimile or computer. The central administrator then enters informationfrom the checklist into the system.

(8) Enrollment of central pharmacy. Central pharmacies that dispense thedrug to authorized treatment sites are enrolled in a tracking systemdescribed herein. Central pharmacies complete an enrollment form, whichis returned to the central administrator. The central administratorenters information from the enrollment form into the system, whichgenerates an authorization for the central pharmacy, which includes,e.g., an authorization number and affiliated authorized treatment sites.

(9) Tracking system. The central administrator systematically followsand actively solicits information on every patient that receives thedrug regarding any adverse events, e.g., any adverse event describedherein. In some embodiments, the central administrator will send astatus form to every prescriber for every patient regularly, e.g., every2, 4, 6, 8, 10 or 12 months. The central administrator will use thestatus forms to ascertain the vital status of the patient and theoccurrence of adverse events and for the prescriber to reauthorize thepatient to continue to receive the drug, e.g., for the next 6 months.The central administrator will enter the data from the status forms intothe database whenever the central administrator receives a status form.

In a preferred embodiment a system described herein includes: a userinterface for inputting a query; and a processor for generating a queryresult.

In a preferred embodiment the method or system is applied to at least50, 100, 500, 1,000, or 10,000 patients.

In another aspect, the invention features, a database useful in a methodof system described herein, e.g., a database containing one or more ofthe forms or elements of information described herein, for each of aplurality of patients.

In a preferred embodiment the database is: disposed on tangible medium;disposed on a single unit of tangible medium, e.g., on a singlecomputer, or in a single paper document; provided on more than one unitof tangible medium, e.g., on more than one computer, in more than asingle paper document, partly on a paper document and partly on computerreadable medium; disposed on computer readable medium; disposed ontraditional medium, e.g., paper, which is readable by a human withoutthe use of a computer, e.g., a printed document, chart, table or cardcatalogue.

All patents, patent applications, and references are hereby incorporatedby reference in their entireties. In the case of conflict, the presentapplication controls.

The details of one or more embodiments of the invention are set forth inthe accompanying drawings and the description below. Other features,objects, and advantages of the invention will be apparent from thedescription and drawings, and from the claims.

DESCRIPTION OF DRAWINGS

FIG. 1 is a schematic of a TYSABRI® drug distribution process.

FIG. 2 is a schematic of a shipping authorization process.

FIG. 3 is a schematic of an enrollment process for prescribers andpatients.

FIG. 4 is a schematic of an infusion site enrollment process.

FIG. 5 is a schematic of a collection and tracking process forPre-infusion Patient Checklist data.

FIG. 6 is a schematic of a central pharmacy enrollment process.

FIG. 7 is a schematic of a TYSABRI® Patient Status Report andReauthorization Questionnaire data collection process.

FIG. 8 is a schematic of data collection in TOUCH Prescribing Program.

FIG. 9 is a block diagram of computing devices and systems.

DETAILED DESCRIPTION

Enrollment

In a preferred embodiment, the method includes enrollment of the patientand, optionally, the prescriber, in the system (referred to above asstep (1)).

This process can begin with the patient and/or prescriber providinginformation, e.g., by filling out a form, e.g., a paper or computerizedform, e.g., a patient and prescriber form, e.g., the Prescriber/PatientEnrollment Form described herein. Examples of the information collectedand of forms that can be used to collect the information are providedherein.

The patient and prescriber form can be supplied by the centraladministrator and is transmitted, e.g., by mail or computer network, tothe prescriber. Both the prescriber and the patient review the form andoptionally indicate assent or agreement by signing it(signing can be bytraditional indication or electronically). Once the decision toprescribe is made, the prescriber and patient will complete and sign theform. After execution by the patient and the prescriber, the completedform is returned to the central administrator, e.g., by facsimile,computer or mail. Submission of the completed form to the centraladministrator registers the patient and the prescriber in the system.

In a preferred embodiment, the patient, e.g., an MS patient, attests toone or more conditions set out herein. For example, the patient atteststo one or more of the following:

-   -   that he/she understands that the drug, e.g., an anti-VLA-4        antibody, e.g., TYSABRI®, is approved for, or only for, a        specific condition, e.g., relapsing forms of multiple sclerosis        (MS);    -   that he/she has read a document that provides preselected        information on the drug, e.g., the anti-VLA-4 antibody, e.g.,        TYSABRI® (an example is the Patient Medication Guide for        TYSABRI® described herein);    -   that he/she is aware that the drug, e.g., the anti-VLA-4        antibody, e.g., TYSABRI®, is associated with a preselected risk,        e.g., an increased risk of progressive multifocal        leukoencephalopathy (PML), which results in an undesirable        outcome, e.g., that usually causes disability and/or death and        that is untreatable;    -   that he/she has discussed the risks and benefits of the drug,        e.g., the anti-VLA-4 antibody, e.g., TYSABRI®, with his/her        physician;    -   that he/she understands that he/she should call his/her        physician promptly to report any continuously worsening        symptoms, e.g., those lasting over several days;    -   that he/she understands that in order to receive the drug, e.g.,        the anti-VLA-4 antibody, e.g., TYSABRI®, he/she will        automatically be enrolled in a registry;    -   that he/she understands that the patient information described        herein may be provided treatment sites, e.g., infusion sites,        other administration sites, or pharmacies involved in his/her        treatment;    -   that he/she understands that if he/she does not complete or sign        this form, he/she will not be able to receive the drug, e.g.,        the anti-VLA-4 antibody, e.g., TYSABRI®; and    -   that he/she agrees to bring to each treatment, e.g., TYSABRI®        treatment, a list of all medications he/she has taken during the        last month.

In a preferred embodiment, the prescriber attests to one or moreconditions set out herein. For example, the prescriber attests to one ormore of the following:

-   -   that he/she will provide the patient, e.g., an MS patient, with        information about the drug, e.g., the Patient Medication Guide        for TYSABRI® (described herein), will require the patient to        read it and will discuss the known risks and potential benefits        of the drug, e.g., the anti-VLA-4 antibody, e.g., TYSABRI®, with        the patient;    -   that he/she has read the full prescribing information for the        drug, e.g., the anti-VLA-4 antibody, e.g., TYSABRI®;    -   that he/she is aware that the drug, e.g., the anti-VLA-4        antibody, e.g., TYSABRI®, increases the risk of a preselected        disorder, e.g., in the case of TYSABRI®, that TYSABRI® increases        the risk of PML, which usually causes disability and/or death        and that is untreatable;    -   that he/she understands that the drug, e.g., the anti-VLA-4        antibody, e.g., TYSABRI®, is indicated for a preselected        purpose, e.g., in the case of TYSABRI®, it is indicated as a        monotherapy for relapsing forms of MS;    -   that he/she will promptly report any case of the preselected        disorder to the central administrator, e.g., in the case of        TYSABRI® treatment, will report any case of PML to the central        administrator;    -   that he/she has discussed the risks and benefits of the drug,        e.g., the anti-VLA-4 antibody, e.g., TYSABRI®, and has discussed        other therapies, with the patient;    -   that he/she has confirmed that the patient has the disorder,        e.g. a relapsing form of MS, using preselected criteria, e.g.,        clinical and radiological criteria;    -   that he/she confirms that the patient has no known        contraindications to the drug, e.g., the anti-VLA-4 antibody,        e.g., TYSABRI®;    -   that he/she is not TYSABRI®, is not prescribing any        antineoplastic, immunosuppressant, or immunotherapies (other        than short courses of corticosteroids) concurrently with        TYSABRI®;    -   that he/she has instructed the patient to promptly report to        his/her prescriber any continuously worsening symptoms that        persist over several days;    -   that he/she agrees to provide any information relating to this        patient that may be necessary to assess the incidence of risk        factors for the preselected disorder (PML in the case of        TYSABRI®) and other adverse affects that may be associated with        the treatment;    -   that he/she is able to diagnose and manage the preselected        disorder (opportunistic infections and PML in the case of        TYSABRI®), or is prepared to refer patients to specialists with        these abilities;    -   that he/she agrees that this patient should be seen and        evaluated at a preselected time after the first administration,        periodically thereafter for as long as the patient receives the        drug, and for at least a preselected number of months after the        drug has been discontinued, e.g., in the case of TYSABRI®,        agrees that this patient should be seen and evaluated 3 months        after the first treatment, 6 months after the first treatment,        at least 6 months thereafter for as long as the patient receives        TYSABRI®, and for at least 6 months after TYSABRI® has been        discontinued;    -   that he/she will determine at a preselected interval whether        this patient should continue on the drug and, if so, authorize        treatment for a preselected period, e.g., in the case of        TYSABRI® treatment, will determine every 6 months whether this        patient should continue on TYSABRI® and if so, authorize        treatment every 6 months; and    -   that he/she understands that the patient and the prescriber will        be automatically enrolled in the registry.

The form can include a prescription for the drug. E.g., in the case ofTYSABRI®, the form can include a preprinted TYSABRI® prescription (1vial; 12 refills; dose 300 mg; directions: IV infusion per PrescribingInformation every 4 weeks). The prescriber has the option of reducingthe number of refills and/or the frequency of dosing on the form. It isthe TYSABRI® Status Report and Reauthorization Process (describedherein) that controls on-going patient re-authorizations, not the numberof refills on the prescription.

The patient and prescriber form can also include one or more of thefollowing: baseline demographic information such as the patient's name,contact information, age, gender, and social security number; theprescriber's name; a diagnosis, e.g., in the case of TYSABRI®, adiagnosis of relapsing MS diagnosis; an indication of the most recentprior therapy, e.g., in the case of TYSABRI®, the most recent prior MStherapy; and a summary of prior exposure to the drug, e.g., TYSABRI®.

Review of Enrollment

In a preferred embodiment, the method includes a review of the patientand prescriber form and its entry into the system. This also includesthe generation of an “approval” (referred to as step (2) above). E.g.,upon receipt at the central administrator, the patient and prescriberform is reviewed, information from it is entered into a computer, and an“authorization form” and unique patient identifier are generated. Thisis described in the section below.

Upon receipt of the patient and prescriber form, the centraladministrator assigns a case manager to the patient, e.g., an MSpatient. The central administrator confirms that the patient and theprescriber have properly executed the patient and prescriber form (andthereby attested to the items described above). After such confirmation,a data entry person enters information from specific fields on thepatient and prescriber form into corresponding fields in a record in thecomputer. Entry of the correct response into a field is required—if suchentry does not occur, the computer will not allow passage to the nextfield or phase of completion. The case manager may assist the data entryperson in this phase. The case manager also matches the patient to atreatment site, e.g., an infusion site (this assignment is based onpatient preference and insurance considerations but is not based on anymedical consideration or judgment) and confirms that the treatment siteis authorized. The computer generates a unique patient enrollment numberfor the patient. This number remains the same for the patient, even ifthe patient de-enrolls and subsequently re-enrolls into the program.

A computer record is started for every patient and prescriber formreceived by the central administrator, even though some patient andprescriber forms may be defective in some way and will not serve to makethe patient eligible to receive drug and will not result in thegeneration of an authorization form, e.g., a Notice of PatientAuthorization Form described herein.

The patient and prescriber form may be defective because it lacks arelevant entry, e.g., the signature by the prescriber or patient, orbecause it includes additional information not requested by the querieson the patient and prescriber form.

The computer generates an authorization, e.g., the authorization form,e.g., the Notice of Patient Authorization Form, if, and only if, allfields on the patient and prescriber form are correctly completed (thusfor each field on the patient and prescriber form, the relevantinformation must be entered into the corresponding “field” in thecomputer). As discussed above, if a field is not correctly filled out inthe computer, the computer will not generate an authorization form,e.g., a Notice of Patient Authorization Form. In this event, the centraladministrator will notify the prescriber and request a completed patientand prescriber form. The new patient and prescriber form will serve toreinitiate the procedure from the beginning

The data entry person will follow a standard-operating-procedure fordealing with patient and prescriber forms that include information otherthan that called for by the patient and prescriber form (e.g., the formincludes handwritten or other attached information), referred to hereinas “annotated patient and prescriber forms.” No approval will begenerated for an annotated patient and prescriber form; rather, theprescriber will be contacted and asked that a new properly completedpatient and prescriber form be filled out and sent to the centraladministrator. The new patient and prescriber form will serve toreinitiate the procedure from the beginning

When all data fields are entered successfully, the computer generates anauthorization, e.g., a Notice of Patient Authorization Form. Theauthorization form can include a computer-generated patient enrollmentnumber.

The computer will include records that correspond to:

-   -   (a) completed patient and prescriber forms;    -   (b) completed patient and prescriber forms where the patient has        decided not to go forward with treatment; and    -   (c) incomplete, annotated or incorrectly answered patient and        prescriber forms.

Records in category (c) will not result in the generation of anauthorization form, e.g., a Notice of Patient Authorization Form.

In the event that the patient changes prescribers, the patient and newprescriber will be required to complete a new patient and prescriberform. The central administrator will inform the treatment site of thechange in prescriber. If the patient does not inform the centraladministrator of such a change, this will be detected in a status form,e.g., the TYSABRI® Patient Status Report and ReauthorizationQuestionnaire described herein.

In the event that the patient changes treatment sites, the centraladministrator will send an authorization form to the new treatment siteand a discontinuation notice, e.g., a Notice of Discontinuation Formdescribed herein, to the old treatment site. If the patient does notinform the central administrator of such a change, this will be detectedby the central administrator when the new treatment site contacts, e.g.,by telephone, the central administrator for approval, e.g., anauthorization form, e.g., a Notice of Patient Authorization. The centraladministrator will update the treatment site data for the patient in thedatabase and will provide an authorization form to the new treatmentsite.

If a prescriber indicates that a patient is lost to follow up, thecentral administrator will attempt to contact the patient. If contact issuccessful and the patient wishes to continue treatment, the patient andthe new prescriber must complete a new patient and prescriber form.Otherwise, the central administrator will communicate to the prescriberand to the treatment site that the patient is de-enrolled.

If a patient re-enrolls, the patient and prescriber must submit a newpatient and prescriber form.

The Treatment Site

Treatment site processing (referred to as step (4) above) is a criticalstep in many embodiments of the invention. As will be clear from thefollowing discussion, the patient enrollment number found on theauthorization form is necessary but not sufficient to allow treatment.In addition to confirming possession of a current authorization form anda patient enrollment number, the treatment site must carry out aspecific procedure, in which a number of issues must be resolved beforethe treatment site can treat, e.g., treat the patient for MS. Thesesteps are described below. One or more of the following steps can beperformed.

-   -   The treatment site must confirm enrollment

Before the treatment site can administer the drug, it must check to seeif the patient is currently authorized to receive the drug, e.g., theanti-VLA-4 antibody, e.g., TYSABRI®. This is performed by the treatmentsite's referring to the patient's medical record and completing thefollowing steps:

-   -   (a) If the patient did not receive his/her previous treatment,        and prescriber clearance was required, the treatment site must        confirm authorization from the prescriber before providing the        current treatment;    -   (b) Confirm that it has a current authorization for the patient        on file (in the case of TYSABRI®, this is a form which states        that the authorization period is 6 months from the first        confirmed treatment). If the authorization form has been lost,        the treatment site can contact, e.g., by telephone, the central        administrator for a replacement authorization form); and    -   (c) Confirm that it does not have a discontinuation notice on        file. (If the central administrator learns that a patient is        de-enrolled from a status form, e.g., the TYSABRI® Patient        Status Report and Reauthorization Questionnaire described        herein, or otherwise from the patient, the central administrator        sends, e.g., by facsimile, a discontinuation notice to the        treatment site. The same information is also telephoned by the        central administrator to the treatment site).    -   The treatment site must provide information about the drug

The treatment site must provide the patient with information about thedrug, e.g., written information, e.g., the Patient Medication Guide forTYSABRI® described herein.

-   -   The treatment site must conduct predetermined investigations        prior to treatment, e.g., the investigations specified on a        checklist, e.g., the Pre-infusion Checklist described herein.        The checklist requires the treatment site ask the following        questions of the patient:    -   i. Over the past month, have you had any new or worsening        medical problems (such as a new or sudden change in your        thinking, eyesight, balance, strength or other problems) that        have persisted over several days?    -   ii. Do you have a medical condition that can weaken your immune        system, such as HIV infection or AIDS, leukemia or lymphoma, or        an organ transplant, that may suggest that you body is not able        to fight infections well?    -   iii. In the past month, have you taken medicines to treat cancer        or MS or any other medicines that weaken you immune system? (A        list on the reverse side of the checklist is reviewed with the        patient.)    -   iv. In the past month, other than the treatment of a recent        relapse, have you taken any of the following medicines:        Solu-Medrol®, methylprednisolone, Decadron®, desamethasone,        Depo-Medrol®, prednisone, or other steroid medicines?

The patient must answer “Yes” or “No” to each of these questions. Basedon the answers there are three possible outcomes: treatment, notreatment or treatment by prescriber “override”.

Treatment Proceeds

If the patent answers “No” to questions 1, 2, 3 and 4 the patient can betreated.

No Treatment or Treatment by Prescriber “Override”

If the patent answers “Yes” (or does not know the answer) to any of 1,2, 3, or 4 the patient cannot be treated without override by theprescriber (or the prescriber's designee). If the answer to any of thesequestions is “Yes”, the prescriber must be contacted for furtherinstructions. After the treatment site discusses the findings with thepatient's prescriber, the prescriber can override and verbally instructthe treatment site to infuse.

The treatment site is required to send the central administrator a copyof the completed checklist, e.g., the Pre-infusion Checklist describedherein. Any authorization by the prescriber must be documented. Thiswill let the central administrator know if the patient was treated. Thechecklist will go into the database and be part of the patient's recordin the database. In some embodiments, the checklist can be computerized,e.g., web-based, for electronic transmission to or electronic access bythe central administrator.

If a treatment site does not comply with these requirements, the centraladministrator will send a warning letter to the treatment site. In theevent of continuing non-compliance, the central administrator willde-list the treatment site and move the patients elsewhere.

Reauthorization

In a preferred embodiment, the method includes reauthorization forcontinued treatment, e.g., treatment of MS. For example, the approvalprovided by the authorization form can last for a maximum of six months.At six month intervals, the central administrator will send, e.g., byfacsimile, the prescriber a status form, e.g., the TYSABRI® PatientStatus Report and Reauthorization Questionnaire described herein.

The prescriber is expected to complete the status form and to return itto the central administrator, e.g., by mail or facsimile. Theinformation from the completed status form will be entered into thecomputer. In some embodiments, the status form can be computerized,e.g., web-based, for electronic transmission to or electronic access bythe central administrator. If the prescriber does not make a timelyreply, the central administrator will send two facsimiles and makemultiple telephone calls to the treatment site.

The status form, e.g., the TYSABRI® Patient Status Report andReauthorization Questionnaire, will ask the following:

-   -   A. Is the patient still under your care?    -   B. Is the patient alive?    -   C. Does the patient have a preselected disorder, e.g., PML, that        you have not already reported to the central administrator?    -   D. Has the patient been hospitalized for a contraindicated        condition, e.g., an opportunistic infection that you have not        already reported to the central administrator?    -   E. Is the patient currently receiving or has the patient        received contraindicated treatment, e.g., intermittent steroids        for the treatment of MS relapse within the last 6 months? (If        “Yes”, how many steroid treatments?)    -   F. Is the patient currently receiving or has the patient        received any immunomodulatory or immunosuppressant products in        the previous 6 months? (If “Yes”, indicate the specific drug and        the number of uses.)    -   G. Do you reauthorize treatment for the next 6 months?

If the answer to Question A is “No”, the central administrator will senda new patient and prescriber form or will initiate the steps todiscontinue the patient from treatment.

If the answer to Question C or D is “Yes” or “Under investigation”, thecentral administrator will contact the prescriber to obtain information

If the answer to Question G is “No”, the central administrator willcontact, e.g., by telephone, the treatment site, the patient, and theprescriber and make sure they know the patient is de-enrolled. Thecentral administrator will also send a discontinuation notice, e.g., aDiscontinuation Notification Form described herein, to the treatmentsite, the patient and the prescriber.

If the answer to Question G is “Yes”, and the answers to Questions C andD are “No”, the central administrator will send a new authorization formto the patient, the prescriber and treatment site. The patient wouldthen show up at the treatment site for his/her next treatment and be putthrough the treatment site process described in step (4) above.

Controlled Distribution System

In a preferred embodiment, the method includes a controlled distributionsystem for the drug, e.g., TYSABRI® (referred to as step (6) above) totreat MS. Under the controlled distribution system, distributors andpharmacies (e.g., specialty and central pharmacies described herein)will each be associated with authorized treatment sites. Thedistributors will sell the drug, e.g., the anti-VLA-4 antibody, e.g.,TYSABRI®, to customers, but will ship the drug only to authorizedpharmacies (e.g., specialty and central pharmacies) or treatment sites.The distributors or specialty pharmacies will ship the drug, e.g., theanti-VLA-4 antibody, e.g., TYSABRI®, only to authorized treatment sitesor their affiliated central pharmacy designated by the centraladministrator. The distributors or specialty pharmacies must obtainshipment authorization, e.g., a shipment authorization code, from thecentral administrator prior to each shipment.

In a preferred embodiment, the method includes only a singledistributor.

In a preferred embodiment, the treatment site receives drug from one thefollowing:

1. Directly from a distributor, which first obtains a shipmentauthorization from the central administrator, which then delivers thedrug from its warehouse to the treatment site;

2. From a central pharmacy (described herein), which would obtain thedrug from a distributor. The distributor first obtains a shipmentauthorization from the central administrator and then delivers the drugfrom its warehouse to the central pharmacy. The central pharmacy thendispenses the drug directly to the authorized treatment site; or

3. From a specialty pharmacy (described herein), which would obtain thedrug from a distributor. The distributor first obtains a shipmentauthorization from the central administrator and then delivers the drugfrom its warehouse to the specialty pharmacy. The specialty pharmacywould then obtain a shipment authorization from the centraladministrator to dispense the drug to the treatment site.

Treatment Site Training

In a preferred embodiment, the method includes training of the treatmentsite, e.g., by the central administrator, relevant to the treatment ofMS with the drug. Prior to treatment site authorization, the centraladministrator will provide training, e.g., on the known risks, potentialbenefits, and appropriate use of the drug, e.g., the anti-VLA-4antibody, e.g., TYSABRI®. The central administrator can use trainingmaterials, e.g., educational materials on the drug and/or itsadministration. The central administrator will instruct the treatmentsites to report adverse events to the central administrator. Inpreferred embodiments, the treatment sites will be required todistribute information about the drug, e.g., the TYSABRI® MedicationGuide described herein, and to conduct one or more of a predeterminedset of queries prior to treatment, e.g., to complete a pre-treatmentchecklist, e.g., a Pre-infusion Patient Checklist described herein. Thetreatment site will then send, e.g., by mail, facsimile, or computer,the completed pre-treatment checklist to the central administrator,e.g., within 4, 8, 12, 24, 48, or 72 hours of the patient's visit,regardless of whether the drug was administered.

In some embodiments, the central administrator enters into the computerdatabase information from the checklist, and the information will belinked to the patient, treatment site and prescriber data in thedatabase. The central administrator will contact the treatment site,e.g., by telephone, to follow-up on incomplete or illegible checklists.If a treatment site does not comply with these requirements, the centraladministrator will send a warning letter to the treatment site. In theevent of continuing non-compliance, the central administrator willde-list the treatment site and move the patients elsewhere, e.g., toanother treatment site.

Central Pharmacies

In some embodiments, the method includes enrollment of centralpharmacies (referred to as step (8) above). As described herein, centralpharmacies are located within, e.g., a hospital, group practice ortreatment site, and are affiliated with a treatment site. Centralpharmacies store drug inventory and release it to a treatment sitelocally.

The central administrator will provide training to central pharmacies byproviding educational materials, e.g., on the distribution system andinventory. The central pharmacy will complete an enrollment form, e.g.,the Central Pharmacy Enrollment Form described herein, and return it tothe central administrator. The central administrator will enter theinformation from the enrollment form into the computer database, atwhich time an authorization number, e.g., a site authorization numberdescribed herein, is assigned to the central pharmacy. The centraladministrator will send, e.g., by facsimile or computer, anauthorization, e.g., a site authorization form, e.g., a SiteAuthorization Confirmation described herein, to the central pharmacy.The site authorization form includes an authorization number and a listof affiliated authorized treatment sites.

Tracking

In some embodiments, the method provides for systematic tracking of alldrug-treated patients. The central administrator will systematicallyfollow and actively solicit information regarding the occurrence of anyadverse event (e.g., PML and other serious opportunistic infections inthe case of TYSABRI®) through a variety of mechanisms on everydrug-treated patient in the US. For example:

-   -   Through periodic collection, e.g., weekly, monthly, or        semi-annually, of pre-treatment checklists described herein, the        central administrator will track drug dosing on an up-to-date,        individual patient basis.    -   On the mandatory patient and prescriber form described herein,        prescribers must attest to report to the central administrator        any case of an adverse event (in the case of TYSABRI®, PML,        other serious OI, or death).    -   On the mandatory patient and prescriber form, patients must        attest that they will report to their prescriber any new or        worsening symptoms that last several days, especially nervous        symptoms. The drug information, e.g., the TYSABRI® Medication        Guide, also provides these instructions to the patient. If the        prescriber determines that the symptoms are related to PML (in        the case of TYSABRI®), then the prescriber is obligated to        report the case to the central administrator.    -   For additional diligence, the central administrator will        actively query prescribers, e.g., every 1 month, e.g., every 2,        3, 4, 5, 6, 8, 10 or 12 months, on each of their patients        regarding the occurrence of an adverse event (in the case of        TYSABRI®, PML, other serious OI, or death) using a status form,        e.g., the TYSABRI® Patient Status Report and Reauthorization        Questionnaire described herein. If a patient discontinues        treatment, the central administrator will actively follow-up on        the status of such a patient.

In some embodiments, the central administrator will send a status form,e.g., a TYSABRI® Patient Status Report and ReauthorizationQuestionnaire, to every prescriber for every patient regularly, e.g.,every 2, 4, 6, 8, 10 or 12 months. The central administrator will usethe status forms to ascertain the vital status of the patient and theoccurrence of adverse events (e.g., PML or other serious OI in the caseof TYSABRI®), and for the prescriber to reauthorize the patient tocontinue to receive the drug, e.g., for the next 6 months. For example,prescribers will be asked whether the patient is still under their care,whether the patient is alive, whether the patient has a diagnosis of PMLor has been hospitalized for an opportunistic infection. In addition,the status form will ask whether the patient is receiving or hasreceived within, e.g., the last 6 months any immunomodulatory orimmunosuppressant therapies, whether the patient is currently or hasreceived within, e.g., the last 6 months any systemic steroids, whetherthe patient has received intermittent steroids within, e.g., the last 6months, and whether the prescriber is authorizing the continuation ofdrug treatment in this patient, e.g., for the next 6 months. The centraladministrator will send the status form to the prescriber, e.g., viafacsimile, mail or computer, who will be expected to complete and returnit to the central administrator, e.g., by facsimile, mail or computer.The central administrator will enter the data from the status forms intothe database whenever the central administrator receives a status form.

The prescriber must reauthorize drug treatment for the patient, e.g.,every 6 months using the status form, e.g., the TYSABRI® Patient StatusReport and Reauthorization Questionnaire. All data fields on the statusform must be completed and the answers appropriate. In addition, theprescriber must authorize the continuation of the drug in order for thepatient to continue to receive drug treatment.

An appropriately completed status form is a requirement for the patientto continue to receive drug treatment. In order for the prescriber to beable to complete this status form, the central administrator expectsthat the prescriber will have recently examined the patient. Byrequiring reauthorization for drug use through the use of this statusform, the central administrator helps to facilitate close clinicalfollow-up of the patient by his/her prescriber, includingpatient-prescriber visits, e.g., every 6 months. Upon reauthorization,an authorization form, e.g., a Notice of Patient Authorization describedherein, will be sent to the prescriber and the treatment site with thenew patient authorization period. Treatment site personnel will confirmthat the patient is currently authorized prior to every treatment.

In a preferred embodiment, the central administrator will follow stepsto determine whether a patient may have discontinued drug treatment.These include:

-   -   A prescriber may complete send to the central administrator,        e.g., by facsimile or computer, a form to discontinue the        patient.    -   Through monthly collection of pre-treatment checklists, e.g.,        Pre-Infusion Patient Checklists, the central administrator will        track drug dosing on an individual patient basis. By diligently        following-up on any missing pre-treatment checklists, the        central administrator will identify any patient who has        discontinued drug treatment.    -   The central administrator will identify patient discontinuations        through the status form, e.g., the TYSABRI® Patient Status        Report and Reauthorization Questionnaire (e.g., if the        prescriber does not authorize the continuation of drug        treatment).    -   The central administrator may also confirm patient        discontinuations through spontaneous reporting by the patient,        prescriber, or treatment site.

EXAMPLES Example 1 Controlled Distribution of TYSABRI® for Relapsing MS

The following example describes a plan for the controlled distributionof TYSABRI® by Biogen Idec. Although the plan refers to Biogen Idec asthe central administrator, it is applicable to any centraladministrator. Although the plan refers to TYSABRI®, the plan can beadapted to other drugs. Although the following plan includes manyfeatures, a plan may include all or a subset of these features as neededfor a particular application.

1. Risk Management Plan Background 1.1 Overview

Biogen Idec (the Sponsor) has developed a comprehensive risk managementplan (RiskMAP), consisting of both risk assessment and a riskminimization features. This document outlines the goals, objectives, andprocesses of the revised TYSABRI® RiskMAP based on discussions with theAgency and the recommendations of the Peripheral and Central NervousSystem Drugs Advisory Committee (Advisory Committee). The TYSABRI®RiskMAP is designed to promote informed risk-benefit decisions betweenprescribers and patients regarding the use of TYSABRI® in relapsingmultiple sclerosis (MS), to minimize morbidity and mortality due toprogressive multifocal leukoencephalopathy (PML) through early detectionwith clinical vigilance, and to minimize the risk of PML by treatingpatients who are not immunocompromised and, consistent with thePrescribing Information (PI), warning against concurrent use withantineoplastics, immunosuppressants or immunomodulators, such asbeta-interferons or glatiramer acetate. In addition, the plan seeks todetermine the incidence and risk factors for PML and other seriousopportunistic infections (OI) in patients treated with TYSABRI®, as wellas the overall safety of TYSABRI® in the clinical practice setting.

This plan has been developed in collaboration with the FDA, inconsideration of FDA's Guidance Document on this topic, and inconsideration of the deliberations of the Advisory Committee. Inaddition, the Sponsor sought extensive feedback from neurologists toobtain their recommendations on how best to minimize the risk of PML,and surveyed many neurologists, MS patients, infusion nurses, infusionsites, and central pharmacies regarding the feasibility of the plan.Biogen Idec has also developed a companion Quality Plan that outlinesthe monitoring of systems and compliance data generated by the RiskMAP.

The TOUCH (TYSABRI® Outreach: Unified Commitment to Health) PrescribingProgram (Table 1) features, among other things:

-   -   Mandatory enrollment of all prescribers and patients into the        TOUCH Prescribing Program, a registry that provides diligent        safety surveillance and systematic tracking of all patients    -   Mandatory training and enrollment of all infusion sites, and all        central pharmacies affiliated with authorized infusion sites,        into the TOUCH Prescribing Program.    -   Controlled distribution system for TYSABRI® so that TYSABRI® is        delivered to and administered only in authorized infusion sites    -   Mandatory completion of the Pre-Infusion Patient Checklist and        distribution of the Medication Guide to each patient prior to        each monthly TYSABRI® dose    -   Real-time submission of Pre-Infusion Patient Checklists to        Biogen Idec to monitor infusion site compliance and to track        TYSABRI® dosing on a patient-specific basis    -   Mandatory prescriber re-authorization of TYSABRI® dosing for        each patient every 6 months    -   At the heart of the TOUCH Prescribing Program is an integrated,        computerized, validated database that captures enrollment,        patient tracking, and drug distribution data.

TABLE 1 TOUCH Program Elements ENROLLMENT TRACKING Patients Pre-InfusionPatient Checklists Physicians Patient Status Report and Infusion SitesReauthorization Questionnaires Central Pharmacies PatientDiscontinuation Questionnaires Single Distributor Follow-Up ofChecklists and ≦Specialty Pharmacies Questionnaires

The RiskMAP primarily seeks to minimize the risk of PML, a rare, butserious, adverse event without creating unintended consequences that mayobstruct appropriate patient access to the potential significantbenefits of TYSABRI®. Once implemented, Biogen Idec will continue toassess the effectiveness of the RiskMAP and the information that itgenerates through a multi-disciplinary TYSABRI® Risk Management ReviewCommittee, report the outcomes to FDA, and act promptly to revise andimprove the plan, as necessary, in order to achieve its goals.

1.2 Risk Management Goals

In consideration of FDA's risk management guidance document, theTYSABRI® RiskMAP incorporates both risk minimization and risk assessmentgoals. The goals of risk minimization are:

-   -   To promote informed risk-benefit decisions regarding TYSABRI®        use in MS patients. Prescribers and their patients should know        that TYSABRI® is associated with an increased risk of PML, which        usually causes death or severe disability. Prescribers should        also know that TYSABRI® is indicated only for the treatment of        relapsing MS.    -   To minimize the risk of PML. To the extent possible, based on        currently available data, patients who are already at risk of        developing PML should not receive TYSABRI® treatment. Patients        who are immunocompromised are at increased risk of developing        PML and, consistent with the PI, generally should not receive        TYSABRI® treatment. In addition, based on limited data, use of        TYSABRI® in combination with antineoplastic, immunosuppressant        or immunomodulatory agents may further increase the risk of PML        compared to TYSABRI® monotherapy. Thus, prescribers should know        that TYSABRI® should not be used concurrently with        antineoplastics, immunosuppressants or immunomodulators.    -   To minimize death and disability due to PML. Although the data        are limited, it is prudent to encourage early detection and        immune-reconstitution in any patient who develops PML in order        to potentially improve patient outcome. Thus, it is important        that prescribers know how to diagnose PML and know to withhold        TYSABRI® dosing immediately at the first signs or symptoms        suggestive of PML. Patients should know to promptly report to        their prescriber any continuously worsening nervous system        symptoms lasting over several days.

The goals of risk assessment are:

-   -   To determine the incidence and risk factors for PML and other        serious opportunistic infections with TYSABRI® treatment. Safety        data from the TOUCH Prescribing Program will support this goal,        as will data from a long-term observational study (TYSABRI®        Global Observational Program in Safety [TYGRIS]).    -   To assess further the overall safety profile of TYSABRI®. Biogen        Idec will continue to study the safety profile of TYSABRI®        beyond 2 years of dosing and in the clinical practice setting,        the nature and incidence of rare unanticipated adverse events,        and the effect of TYSABRI® on humoral and cell-mediated        immunity. Safety data from the TOUCH Prescribing Program,        TYGRIS, and TYSABRI® clinical trials will support this goal.

1.3 Important Features of Medical Management of MS Patients

There are several important aspects about the medical management ofpatients with MS and the administration of TYSABRI® that allow forsuccessful implementation of the Risk Minimization Action plan(RiskMAP).

1. TYSABRI® is Prescribed by Prescribers Who Specialize in the Care ofPatients with MS.

In the United States, patients with MS receive medical treatment by arelatively small group of physicians, primarily neurologists.Approximately 6,000 physicians treat 90% of patients with MS. This is incontrast to 170,000 family practitioners that treat primary carediseases in the US. Biogen Idec has a dedicated force of physicians andsales representatives that interact with neurologists and otherhealthcare professionals who care for patients with MS. Consequently,Biogen Idec can readily reach nearly all prescribers who are expected toprescribe TYSABRI®.

Because PML is a disease of the central nervous system, the targetedprescribers of TYSABRI® are also the best-qualified physicians todiagnose and manage PML. Neurologists have the expertise to monitorsubjects for signs and symptoms indicative of PML and select appropriatediagnostic tests to diagnose a patient with PML.

2. Patients with MS are Knowledgeable About Their Treatment Options.

Patients with MS are generally a young, highly motivated patientpopulation. In a recent survey, 94% to 99% of patients with MS wereaware of their treatment options, including beta-interferons andglatiramcr acetate (GA) (Biogen Idec, data on file). During the periodwhen TYSABRI® was available commercially, Biogen Idec found that 79% ofpatients with MS were aware of the introduction of TYSABRI®. Also,Biogen Idec has sought feedback from patients with MS and found that thepotential risk of PML with TYSABRI® has been broadly disseminated in theMS community. Based on Biogen Idec's market research, patients with MSwant to learn more about the risks of PML with TYSABRI®.

3. Discussion of Risks and Benefits Associated with MS Treatment is theStandard of Care in Neurology Practice.

Prescribing a disease-modifying treatment for a serious, disablingdisease such as MS is a carefully considered and deliberate decision.Based upon feedback from neurologists and MS patients, this decisionusually involves a detailed discussion between the prescriber andpatient about the risks and benefits of available therapies. Someneurologists already use an informed-consent form prior to initiatingtherapy with an immunomodulatory agent such as interferon-beta orglatiramer acetate. The TYSABRI® risk minimization strategy builds uponthis existing decision-making process.

4. TYSABRI® is Administered Monthly by Healthcare Professionals inInfusion Sites.

In contrast to therapies that are self-administered in the patient'shome, TYSABRI® is administered intravenously every month at an infusionsite under the care and management of infusion nurses. This regulated,procedure-oriented dispensing environment allows for monthly monitoringof patients for potential symptoms suggestive of PML and for effectivedissemination of information on TYSABRI® that reinforces appropriateuse.

The TOUCH Prescribing Program is designed to inform prescribers,infusion nurses, and MS patients about the risk of PML and how tominimize that risk. A RiskMAP system of mandatory enrollment of allprescribers and patients, controlled distribution of TYSABRI®, andadministration of TYSABRI® only in trained and authorized infusion siteswas developed to build upon the unique aspects of the medical managementof MS patients and the administration of TYSABRI®.

2. Controlled Distribution System for TYSABRI®

Biogen Idec and Elan have designed a controlled distribution system todeliver TYSABRI® only to infusion sites (or, if appropriate, theiraffiliated central pharmacies) that have been trained by Biogen Idec orElan personnel on the known risks and appropriate use of TYSABRI®, usingeducation tools1, and have attested that they will follow the RiskMAPrequirements (See Section 4.2 and 4.3). The controlled distribution ofTYSABRI® will allow Biogen Idec and Elan to track TYSABRI® shipments,i.e., the location and number of vials shipped to infusion sites andcentral pharmacies. 1 As requested by the FDA, prior to distributingeducation materials relating to the RiskMAP, the Sponsor shall submitthem for FDA review.

2.1 Distribution System Description

Under the controlled distribution plan, a single distributor, specialtypharmacies, and central pharmacies will each be associated withauthorized infusion sites. Elan has contracted with a single distributorand will contract with a limited number of specialty pharmacies (≦12) todistribute TYSABRI® only to authorized infusion sites. The singledistributor will sell TYSABRI® to its customers, but only ship productto authorized specialty pharmacies, central pharmacies or infusionsites.

The single distributor and participating specialty pharmacies will becontractually obligated to follow RiskMAP requirements in order topurchase and distribute TYSABRI®. The contracts will specify, amongother requirements, that:

-   -   TYSABRI® will be shipped only to authorized infusion sites (or        their authorized affiliated central pharmacy) designated by        Biogen Idec and Elan, either directly from the single        distributor or through one of the specialty pharmacies.    -   A shipment authorization code must be obtained from Biogen Idec        and Elan for each shipment prior to each shipment.

Specialty pharmacy providers are organizations that dispense specialtyproducts, including injectable and infusible therapies. Product islabeled with the patient's name, and is typically dispensed directly toan authorized infusion site (e.g., physician's office or other infusionsite).

Central pharmacies are distinct from specialty pharmacies. A centralpharmacy is located within a hospital, group practice or infusion site,and is affiliated with an infusion site. The central pharmacy isresponsible for purchasing, storing, and dispensing product to itsaffiliated infusion site. Biogen Idec will provide each authorizedcentral pharmacy with a list of the authorized infusion sites to whichit may release product. The central pharmacy may only dispense productto these authorized sites and must maintain a TOUCH Central PharmacyInventory Tracking Log. This log is meant to document each instanceTYSABRI® is released by the central pharmacy, including the number ofvials released and the infusion site (including its unique SiteAuthorization Number) that received the product. The Central Pharmacyshould retain its Inventory Tracking Logs for 5 years.

2.2 Distribution System Process

The TYSABRI® shipment and authorization process is illustrated inFIG. 1. There are three ways in which an infusion site can receiveproduct. A shipment authorization is required prior to shipment in eachof these cases.

1. Infusion site obtains product directly from the single distributor.The single distributor would obtain a shipment authorization from BiogenIdec and Elan, and deliver TYSABRI® directly from the single distributorwarehouse to the infusion site.

2. Infusion site utilizes an affiliated central pharmacy. The centralpharmacy would obtain TYSABRI® from the single distributor. The singledistributor would obtain a shipment authorization from Biogen Idec andElan, and deliver TYSABRI® directly from the single distributorwarehouse to the central pharmacy. The central pharmacy will thendispense TYSABRI® directly to the authorized infusion site.

3. Infusion site obtains TYSABRI® from a specialty pharmacy. Thespecialty pharmacy would obtain TYSABRI® from the single distributor.The single distributor would obtain a shipment authorization from BiogenIdec and Elan, and deliver TYSABRI® directly from the single distributorwarehouse to the specialty pharmacy. The specialty pharmacy would thenobtain a shipment authorization from Biogen Idec and Elan to dispenseTYSABRI® to the infusion site.

2.3 Shipment Authorization

Biogen Idec and Elan will permit TYSABRI® delivery only to authorizedinfusion sites and only in quantities justified by the number ofauthorized patients at the site. Biogen Idec will maintain the list ofauthorized sites (authorized infusion sites and authorized centralpharmacies) in the TOUCH database as described in Sections 4.4 and 5.2.An acceptable order quantity will be established on a site-by-site basistaking into account the amount of drug previously shipped to the siterelative to the confirmed and expected demand from enrolled patients atthe site.

As described in FIG. 2, when the single distributor receives an orderfrom an infusion site, the single distributor would first confirm thatthe order quantity is less than the maximum acceptable order for thatsite. Then, the single distributor will access the TYSABRIdirect.com website and enter the infusion site or central pharmacy address thatTYSABRI® will be shipped to. The web site will access the TOUCH databaseand if the “ship to” address that the single distributor entered matchesan authorized infusion site (or affiliated authorized central pharmacy),a shipment authorization code will be provided to the centraldistributor and will be captured in the TOUCH database. Specialtypharmacies follow the same process of authorization based on the “shipto” address, but are not required to confirm order quantity because theyonly dispense on a per patient basis. The single distributor and SPPsmust not ship TYSABRI® without a shipment authorization code.

2.4 Shipping Data Provided by Single Distributor and SpecialtyPharmacies

The single distributor and specialty pharmacies will be required toprovide shipment authorization codes as well as other informationcritical to monitoring shipments to authorized infusion sites andinventory levels on a weekly basis to Biogen Idec and Elan, including:

-   -   Central Distributor information: unique identifier, name,        invoice number, location shipped from    -   SPP information: unique identifier, name, location shipped from    -   Shipment information: quantity shipped, quantity returned, date    -   Ship-to information: identifier, name, address, class of trade    -   Shipment authorization code: as obtained from TOUCH database for        each shipment

2.5 Reconciliation of Shipping Addresses and Quantities

Biogen Idec and Elan will reconcile the shipping addresses that havereceived TYSABRI® shipments against the list of authorized sites on anon-going basis. Biogen Idec will reconcile, at least monthly, the amountof drug shipped to each site compared to the expected volume ofinfusions for that site. These site reconciliations will be conducted byanalyzing beginning inventory balances, product shipped during thereconciliation period, product returns, and the number of confirmedpatient infusions. Any discrepancies identified by this reconciliationwould be flagged for further investigation. Such investigations couldinclude for-cause audits of physical inventory on an as-needed basis toconfirm that the calculated inventory level at a site is consistent withthe actual inventory level. This combination of ongoing reconciliationand follow-up investigations is intended to enable management of lowinventory levels across the distribution system.

Reconciliations will also be performed with central pharmacy data.Product shipped into the Central Pharmacy will be reconciled againstconfirmed infusions of authorized patients at the affiliated authorizedinfusion sites, at least monthly. In addition, Biogen Idec will examinea sample of inventory tracking logs and reconcile them with shippingdata to measure central pharmacy compliance.

3 Mandatory Enrollment of Prescribers and Patients

A key feature of the RiskMAP is mandatory enrollment of all prescribersand patients into the TOUCH Prescribing Program as a prerequisite toprescribing or receiving TYSABRI® treatment.

3.1 Prescriber/Patient Enrollment Form

Prescribers and patients must complete and sign a mandatoryPrescriber/Patient Enrollment Form and send it to Biogen Idec prior toinitiating TYSABRI® treatment.

The purpose of the Prescriber/Patient Enrollment Form is to help assurethat (1) both the prescriber and patient are informed of the known risksof TYSABRI®, including the risk of PML, (2) TYSABRI® is prescribed onlyfor appropriate patients, and (3) that patients will be trackedlongitudinally for safety outcomes.

The Prescriber/Patient Enrollment Form will be used to collect baselinedemographic information including the prescriber's name and contactinformation, patient's name, contact information, age, gender, socialsecurity number, relapsing MS diagnosis, most recent prior MS therapy;prior TYSABRI® exposure; a TYSABRI® prescription; and aPatient-Prescriber Acknowledgement.

The TYSABRI® prescription is pre-printed as a 300 mg dose to beadministered by IV infusion every 4 weeks, with 12 refills/doses. Theprescriber has the option of reducing the number of refills and/or thefrequency of dosing on the Enrollment form. Prescribers are able tode-enroll patients at any time, notwithstanding the number of refillsindicated on this prescription. It is the TYSABRI® Status Report andReauthorization process (described in Section 6.3 and 6.4) that controlson-going patient re-authorizations, not the number of refills on theprescription.

Biogen Idec will require that, prior to starting TYSABRI® treatment, theprescriber will provide the patient with the TYSABRI® Medication Guide,will require the patient to read it, and will discuss the known risksand potential benefits of TYSABRI® with the patient. Once the decisionto prescribe TYSABRI® is made, the prescriber and patient will completeand sign the Prescriber/Patient Enrollment Form. The completed andsigned Enrollment Form must be faxed to Biogen Idec before theprescriber may prescribe TYSABRI® and the patient may receive aninfusion. Biogen Idec will have mail and fax options to send and receiveforms. By signing the Enrollment Form, the patient and the prescriberacknowledge the following:

Patient Acknowledgement

I acknowledge that:

TYSABRI® is a medicine approved only to treat patients with relapsingforms of multiple sclerosis (MS).

-   -   TYSABRI® is generally recommended for patients who have not been        helped enough by, or cannot tolerate other treatments for MS    -   I have talked to my doctor and understand the benefits and risks        of TYSABRI® treatment

TYSABRI® increases your chance of getting a rare brain infection thatusually causes death or severe disability.

-   -   This infection is called progressive multifocal        leukoencephalopathy (PML). PML usually happens in people with        weakened immune systems    -   No one can predict who will get PML. There is no known        treatment, prevention, or cure for PML    -   My chance for getting PML may be higher if I am also being        treated with other medicines that can weaken my immune system,        including other MS treatments.    -   Even if I use TYSABRI® alone to treat my MS, it is not known if        my chance for getting PML will be lower. It is also not known if        treatment for a long period of time with TYSABRI® can increase        my chance for PML    -   I should call my doctor right away if I get any new or worsening        symptoms that last several days, especially nervous system        symptoms. Some of these symptoms include a new or sudden change        in my thinking, eyesight, balance, or strength, but I should        also report other new or worsening symptoms

To receive TYSABRI®, all patients must be authorized in a specialprogram called the TOUCH Prescribing Program.

-   -   The TOUCH Prescribing Program is run by the company that makes        TYSABRI®. The company will collect information about my health        at regular time periods. I cannot receive TYSABRI® if I do not        agree to follow the requirements of the TOUCH Prescribing        Program    -   I must notify the TOUCH Prescribing Program if I switch        prescribers or infusion sites    -   I have received, read, and understand the Patient Medication        Guide    -   I will bring to each TYSABRI® infusion a list of all medicines        and treatments that I have taken during the last month

Prescriber Acknowledgement

I acknowledge that:

-   -   I have read and understand the full Prescribing Information for        TYSABRI®    -   TYSABRI® is indicated as monotherapy for relapsing forms of MS    -   This patient has a relapsing form of MS based on clinical and        radiological evidence    -   TYSABRI® increases the risk of progressive multifocal        leukoencephalopathy (PML), an opportunistic viral infection of        the brain that usually leads to death or severe disability.        Although the cases of PML were limited to patients with recent        or concomitant exposure to immunomodulators or        immunosuppressants, there were too few cases to rule out the        possibility that PML may occur with TYSABRI® monotherapy    -   I am able to diagnose and manage opportunistic infections and        PML, or am prepared to refer patients to specialists with these        abilities    -   Because TYSABRI® increases the risk of PML, it is generally        recommended for patients who have had an inadequate response to,        or are unable to tolerate, alternate MS therapies. I have        discussed other MS treatments with this patient    -   TYSABRI® is not ordinarily recommended for patients who are        receiving chronic immunosuppressant or immunomodulatory therapy,        or who are significantly immunocompromised from any other cause    -   This patient has no known contraindications to TYSABRI®        treatment, including PML    -   I have instructed the patient to promptly report to me any        continuously worsening symptoms that persist over several days    -   This patient should be seen and evaluated 3 months after the        first infusion, 6 months after the first infusion, at least        every 6 months thereafter for as long as the patient receives        TYSABRI®, and for at least 6 months after TYSABRI® has been        discontinued    -   I will determine every 6 months whether this patient should        continue on TYSABRI® and if so, authorize treatment every 6        months    -   I should report, as soon as possible, any case of PML, any        hospitalization due to opportunistic infection, and any death to        Biogen Idec    -   Data concerning this patient and me will be entered into the        mandatory TOUCH Prescribing Program. Biogen Idec requires my        cooperation with periodic data collection. Failure to provide        the requested information or otherwise comply with the        requirements of the TOUCH Prescribing Program may result in        discontinuation of TYSABRI® treatment for this patient and        forfeiture of my authorization to prescribe TYSABRI®    -   I have received educational materials regarding the benefits and        risks of TYSABRI® treatment    -   I have, or another healthcare provider under my direction has,        educated this patient on the benefits and risks of treatment        with TYSABRI®, provided him or her with the Patient Medication        Guide and Enrollment Form, instructed him or her to read these        materials, and encouraged him or her to ask questions when        considering TYSABRI®

3.2 Enrollment Process for Prescribers and Patients

Biogen Idec will maintain the complete list of prescribers and patientsauthorized in the TOUCH Prescribing Program in the TOUCH database.

As described in FIG. 3, Biogen Idec will review the submittedPrescriber/Patient Enrollment Form for completeness and accuracy, andverify that both the prescriber and the patient have signed the form.The prescriber and patient information will be entered into the TOUCHdatabase. Biogen Idec will confirm the patient name, social securitynumber (if provided) and date of birth against all current and previouspatients in the database in order to avoid duplicate entries. At thattime, a unique Patient Enrollment Number will be assigned to the patientin the TOUCH database, which should remain the same for that patient,even if the patient de-enrolls and subsequently re-enrolls into theprogram. Biogen Idec will assign a case manager to the patient. ThenBiogen Idec will match the patient to an authorized infusion site, orconfirm that the infusion site to which the prescriber has referred thepatient is authorized in the TOUCH Prescribing Program.

Biogen Idec will communicate initial patient enrollment to both theinfusion site and prescriber by means of a Notice of PatientAuthorization fax. The infusion site will use this Notice of PatientAuthorization to verify patient enrollment in the TOUCH PrescribingProgram before administering the first dose of TYSABRI® to the patient.After the infusion site notifies Biogen Idec that the first dose hasbeen administered (see Section 4.6), Biogen Idec will communicatecurrent patient enrollment status to both the infusion site and theprescriber by means of a second Notice of Patient Authorization fax. Thepatient authorization period stated on this second fax is 6 months fromthe first confirmed infusion. Both the start and stop date of theauthorization period are noted on the fax. If an infusion site misplacesthe Notice of Patient Authorization fax, they may call Biogen Idec at1-800-456-2255 and request a replacement Notice of Patient Authorizationfax.

The prescriber must complete and sign a new Prescriber/PatientEnrollment Form for every patient of his or hers that enrolls into theTOUCH Prescribing Program. In addition, after a patient has authorized,the prescriber must reauthorize TYSABRI® use for that patient every 6months, as described in Section 6.5.

3.3 Process for Patients Who Change Prescribers

Patients attest on the Prescriber/Patient Enrollment Form that they willinform Biogen Idec when and if they change prescribers. The patient willbe required to complete a new Prescriber/Patient Enrollment Form withthe new prescriber to ensure that the new prescriber is authorized inthe TOUCH Prescribing Program, and that the patient and new prescriberhave discussed the known risks and potential benefits of TYSABRI®treatment. Biogen Idec will then inform the infusion site of the changein prescriber. If a patient does not inform Biogen Idec when he/shechanges prescribers, Biogen Idec will obtain this information during theTYSABRI® Patient Status Report and Reauthorization Questionnaire process(see Section 6.3).

3.4 Process for Patients Who Change Infusion Sites

Patients attest on the Prescriber/Patient Enrollment Form that they willinform Biogen Idec if they change infusion sites. If a patient changesinfusion sites, Biogen Idec will verify that the new infusion site isauthorized in the TOUCH Prescribing Program and then Biogen Idec willsend a Notice of Patient Authorization fax with the patient's enrollmentnumber and authorization period to the new infusion site and theprescriber. Biogen Idec will send Notice of Discontinuation to theprevious infusion site stating that the patient is no longer eligible toreceive treatment at that site. In the event that the patient changesinfusion sites and does not inform Biogen Idec, Biogen Idec willidentify this information when the new infusion site contacts BiogenIdec to obtain the Notice of Patient Authorization. Upon notice of thenew infusion site, Biogen Idec will update the infusion site data linkedto the patient in the TOUCH database and provide the new infusion sitewith the Notice of Patient Authorization Fax.

3.5 Process for Patients Who are Hospitalized

If a patient is hospitalized and due for his or her next infusion, thepatient may receive TYSABRI® at an authorized infusion site within thehospital if medically appropriate. The patient must be physically movedto the authorized infusion site to receive TYSABRI® under the care ofthe trained personnel who will administer the infusion. The authorizedinfusion site will contact Biogen Idec to obtain the Notice of PatientAuthorization for that patient. If the hospital does not have anauthorized infusion site, the infusion should be deferred until thepatient is discharged and able to return to his or her usual authorizedinfusion site.

3.6 Prescriber De-Enrollment from the TOUCH Prescribing Program

By signing the Prescriber/Patient Enrollment Form, prescribers willacknowledge that a significant pattern of non-compliance with therequirements of the RiskMAP may result in his or her de-enrollment fromthe TOUCH Prescribing Program and forfeiture of authorization toprescribe TYSABRI®. Affected patients will be directed to otherauthorized prescribers in the area; if this is not possible, then theaffected patients could potentially be de-authorized as well (seeSection 10.3.2)

3.7 Patient Discontinuation from the TOUCH Prescribing Program

If a patient discontinues TYSABRI® treatment as indicated on theTYSABRI® Patient Status Report and Reauthorization Questionnaire(described in Section 6.4), or by notifying Biogen Idec, Biogen Idecwill call the infusion site, communicate the patient's discontinuation,confirm the patient is not scheduled for future TYSABRI® infusions andsend a Notice of Discontinuation to the prescriber, patient and infusionsite stating that the patient is no longer authorized in the TOUCHPrescribing Program, and is not authorized to continue TYSABRI®treatment. Biogen Idec will document these calls to the infusion site.

If a prescriber indicates that a patient is lost to follow-up, BiogenIdec will attempt to contact that patient. If the patient plans tocontinue TYSABRI®-treatment, he/she will be instructed to contact his orher new prescriber to complete a new Prescriber/Patient Enrollment form.If this new Prescriber/Patient Enrollment form is not completed, BiogenIdec will communicate to the prescriber, patient and infusion site thatthe patient is no longer authorized in the TOUCH Prescribing Program,and is not authorized to continue TYSABRI® treatment. If Biogen Idec isunable to contact the patient, we will communicate to the prescriber andinfusion site that the patient is no longer authorized to receiveTYSABRI® treatment (see Section 10.3.2).

Prescribers will be required to complete a Patient DiscontinuationQuestionnaire when a patient discontinues TYSABRI® and 6 months afterthe patient discontinues TYSABRI®, as outlined in Section 6.8.

3.8 Re-Enrollment into the TOUCH Prescribing Program

A patient who is interested in re-starting TYSABRI® treatment isrequired to complete a new Prescriber/Patient Enrollment Form with hisor her prescriber. Biogen Idec will follow the same enrollment processesto assist the patient in starting therapy. The patient will have thesame unique Patient Enrollment Number as before, so that Biogen Idec canmeasure each patient's exposure to TYSABRI® over time. Therefore, thepatient's new enrollment is linked to his or her prior enrollment, andBiogen Idec will be able to measure a patient's TYSABRI® exposure overtime, or during a particular enrollment period.

4 Mandatory Training and Enrollment of Infusion Sites

TYSABRI® will be shipped only to and administered only at infusion sitesauthorized in the TOUCH Prescribing Program. Authorized infusion sitesare sites that have been trained by Biogen Idec and Elan on the knownrisks, potential benefits and appropriate use of TYSABRI®, usingeducational materials. The infusion sites must also agree to comply withthe RiskMAP requirements.

4.1 Criteria for Selection of Infusion Sites

Biogen Idec estimates that, after completion of the infusion sitetraining, approximately 2,000 infusion sites will become authorized toadminister TYSABRI®. An infusion site can be located in a hospital, astand-alone clinic, or a physician's office. Infusion sites will beselected based on capability to execute the required RiskMAP activities,as well as patient need and geography. Biogen Idec and Elan will try toassure that each geographic region has an adequate number of authorizedinfusion sites to provide appropriate patients access to TYSABRI®therapy.

4.2 Training of Infusion Sites

Biogen Idec and Elan representatives will visit infusion sites, prior totheir authorization, and provide training on the known risks, potentialbenefits, and appropriate use of TYSABRI® using the various TOUCHdocuments, including TOUCH Education Slide Set, Pre-infusion PatientChecklist, and Medication Guide. Infusion sites will be instructed thathealthcare providers should promptly report serious adverse events toBiogen Idec. Infusion sites will be required to distribute the TYSABRI®Medication Guide and complete a Pre-infusion Patient Checklist for eachpatient prior to each monthly infusion and forward the Pre-infusionPatient Checklist including the date of infusion to Biogen Idec.

4.3 Infusion Site Enrollment Form

To enroll in the TOUCH Prescribing Program, the infusion site completesand signs the Infusion Site Enrollment Form. The infusion site willdesignate a person with appropriate authority to sign the Infusion SiteEnrollment Form on behalf of the infusion site. The infusion site mustacknowledge the following:

Infusion Site Acknowledgement

-   -   A representative of Biogen Idec or Elan Pharmaceuticals, Inc.        has provided training and education materials on the TOUCH        Prescribing Program    -   TYSABRI(R) will be administered only to patients who are        enrolled in the TOUCH Prescribing Program    -   Only currently authorized patients will receive TYSABRI®.        Authorization is confirmed by ensuring that there is a current        Notice of Patient Authorization on file and that the site has        not received a Notice of Patient Discontinuation.    -   Each patient will receive a copy of the TYSABRI® Patient        Medication Guide prior to each infusion

A TYSABRI® Pre-infusion Patient Checklist must be completed for everypatient scheduled to receive TYSABRI®. The Pre-infusion PatientChecklist must be faxed to Biogen Idec within 1 business day of patientvisit, and a copy placed in the patient's medical record

-   -   I understand that, per the requirements of the TOUCH Prescribing        Program, this infusion site may be audited by the Food and Drug        Administration (FDA), Biogen Idec, Elan Pharmaceuticals, Inc.,        and/or a third party designated by the FDA, Biogen Idec, or Elan        Pharmaceuticals, Inc.    -   Noncompliance with the requirements of the TOUCH Prescribing        Program will result in de-enrollment of the infusion site and        forfeiture of the authorization to infuse TYSABRI®

After completing and signing the Infusion Site Enrollment Form, theinfusion site faxes it to Biogen Idec.

4.4 Infusion Site Enrollment Process

Biogen Idec will maintain the complete list of authorized infusion sitesin the TOUCH database.

As described in FIG. 4, when Biogen Idec receives the Infusion SiteEnrollment Form, Biogen Idec will verify that the form is complete,accurate and signed. Then Biogen Idec will enter the infusion siteinformation into the TOUCH database, thus initiating enrollment andauthorization of the infusion site in the TOUCH Prescribing Program. Atthat time, a unique Site Authorization Number will be assigned to theinfusion site in the TOUCH database and Biogen Idec will fax a SiteAuthorization Confirmation. The infusion site will be instructed to usethe Site Authorization Number when ordering TYSABRI®. If an infusionsite misplaces the Site Authorization Confirmation fax, the site maycall Biogen Idec at 1-800-456-2255 to request a copy.

4.5 Pre-Infusion Patient Checklists

Prior to each infusion, an authorized infusion site must verify thepatient is currently authorized to receive TYSABRI® treatment from themedical record. In order to do this, the site must refer to thepatient's medical record and complete the following steps prior to everyinfusion.

-   -   1. If the patient did not receive his or her previous infusion,        and physician clearance was required, the site must confirm        authorization from the prescriber before providing the current        infusion.    -   2. Confirm that there is a current Notice of Patient        Authorization on file and verify the infusion is within the        current authorization period.    -   3. Confirm there is not a Notice of Discontinuation on file. As        stated previously in Section 3.7, if the patient discontinues        TYSABRI®, Biogen Idec will call the infusion site, communicate        discontinuation, confirm the patient is not scheduled for future        TYSABRI® infusions and send a Notice of Discontinuation to the        prescriber, patient and infusion site stating that the patient        is no longer authorized in the TOUCH Prescribing Program, and is        not authorized to continue TYSABRI® treatment. Biogen Idec will        document these calls to the infusion site.

Only if the patient is authorized to receive TYSABRI®, the site nextprovides the patient with the TYSABRI® Medication Guide, gives thepatient time to read the Medication Guide, and completes thePre-Infusion Patient Checklist.

Infusion nurses will be instructed to complete the Pre-infusion PatientChecklist for each patient prior to each TYSABRI® infusion.

In order to assure that patient care is not jeopardized due to latecommunication of reauthorization, infusion sites will be allowed toprovide one infusion past the authorization date. If a patient presentsoutside of the authorized period, the infusion site is required to callBiogen Idec. Biogen Idec will record all infusions that take placeduring this period.

The Pre-infusion Patient Checklist is designed to minimize inappropriateuse of TYSABRI® and to facilitate early detection of worseningneurological symptoms that might be indicative of PML through regular,monthly assessments by infusion nurses at infusion sites. Using thePre-Infusion Checklist, the infusion nurse is instructed to ask thefollowing questions to the patient:

Pre-Infusion Patient Checklist Questions:

-   -   1. Over the past month, have you had any new or worsening        medical problems (such as a new or sudden change in your        thinking, eyesight, balance, strength, or other problems) that        have persisted over several days?    -   2. Do you have a medical condition that can weaken your immune        system, such as HIV infection or AIDS, leukemia or lymphoma, or        an organ transplant, that may suggest that your body is not able        to fight infections well?    -   3. In the past month, have you taken medicines to treat cancer        or MS or any other medicines that weaken your immune system?        (Review the list on the reverse side with the patient.)    -   4. In the past month, other than for the treatment of a recent        relapse, have you taken any of the following medicines:        Solu-Medrol®, methylprednisolone, Decadron®, dexamethasone,        Depo-Medrol®, prednisone, or other steroid medicines?

If the patient answers NO to questions 1, 2, 3, and 4, the patient maybe infused. If the patient answers YES (or the patient does not know theanswer) to any of questions 1, 2, 3, or 4, then the patient should notbe infused at that time, and the prescriber should be contacted forfurther instructions. After the infusion nurse discusses the findingswith the patient's prescriber, the prescriber may give authorization toproceed with the infusion. Otherwise, the infusion must not be given andthe patient must be promptly referred to their prescriber for furtherevaluation. The infusion nurse must document if authorization was given,and for all patients, the infusion nurse will document whether or notthe patient was infused. The Pre-Infusion Patient Checklist must befaxed to Biogen Idec regardless of whether or not the patient receivedthe infusion.

Thus, the Pre-Infusion Patient Checklist is designed to trigger aneurologist's consultation if the patient reports any worseningneurological symptoms lasting several days, if the patient reports anymedical condition that may lead to an immunocompromised state (e.g., HIVinfection), or if the patient reports receiving any concurrentimmunomodulatory or immunosuppressant therapies, or steroid use.

4.6 Real-Time Centralized Collection and Tracking of Pre-InfusionPatient Checklists

So that the Sponsor may monitor infusion site compliance with completionof the Pre-Infusion Patient Checklist and track infusions on areal-time, patient-specific basis, the infusion site must fax thePre-Infusion Patient Checklist to Biogen Idec within 1 business dayafter the patient's infusion visit, whether the patient received theTYSABRI® infusion or not.

As described in FIG. 5, the Pre-Infusion Patient Checklist data will beentered into the TOUCH database whenever Biogen Idec receives aPre-Infusion Patient Checklist. The Pre-Infusion Patient Checklist datawill be linked to the patient, infusion site and prescriber data in theTOUCH database. A history of Pre-Infusion Patient Checklist data will betracked for each patient, each infusion site and each prescriber.

In a later phase of the program, infusion sites may be able to use aweb-based system to directly enter the Pre-Infusion Patient Checklistdata into the TOUCH database, or continue to fax to Biogen Idec. Thisweb-based system may simplify monitoring of compliance with the TOUCHPrescribing Program and tracking of individual patient dosing.

4.7 Diligence with Follow-Up of Missing Pre-Infusion Patient Checklists

Biogen Idec will make diligent efforts to obtain a completedPre-Infusion Patient Checklist from every infusion site on every patientevery month.

The Pre-Infusion Patient Checklist asks for the next scheduled infusiondate, which will assist Biogen Idec in targeting when the next infusionwill be given. If a date of next infusion is provided, Biogen Idec willfollow-up on a missing Pre-Infusion Patient Checklist 3 days after thatdate.

If this next scheduled infusion date field is left blank, Biogen Idecwill follow-up with the infusion site 45 days after the previousinfusion, based on the following assumptions. The TYSABRI® approved PIwill indicate that infusions are administered every 4 weeks. Assuming a14-day window to allow for patient scheduling variation and anadditional 3 days for variability surrounding the infusion sitesubmission of the completed Pre-Infusion Patient Checklist, Biogen Idecexpects to receive almost all completed Pre-Infusion Patient Checklistswithin 45 days after the previous infusion. If the Pre-Infusion PatientChecklist has not been submitted within this timeframe, Biogen Idec willtelephone the infusion site in order to determine whether:

-   -   1. The patient has received a TYSABRI® infusion but the infusion        site has not yet submitted the Pre-Infusion Patient Checklist,        OR    -   2. The infusion appointment is scheduled to occur shortly, OR    -   3. The patient did not come to his or her scheduled infusion        appointment

In the case of (1), Biogen Idec will request that the infusion site sendin the completed checklist and will remind the infusion site that achecklist must be completed on every patient before every dose andpromptly submitted to Biogen Idec. Significant non-compliance on thepart of the infusion site may result in de-enrollment of the infusionsite and forfeiture of the authorization to administer TYSABRI® (seeSection 10.3.2 for De-Enrollment Process).

In the case of (3), Biogen Idec will contact the prescriber to determinewhether the patient is alive, whether the patient is receiving TYSABRI®,and whether the patient has developed PML or other serious OI. Ifattempts to obtain information from the prescriber are unsuccessful,then Biogen Idec will attempt to contact the patient directly in orderto determine if the patient is alive, whether the patient is on TYSABRI®treatment, whether the patient has been hospitalized, and to remind thepatient to contact his or her prescriber. If the patient has died, hasPML, or other serious OI, or has been hospitalized, the Biogen Idec DrugSafety will diligently investigate the case and report to the FDA asappropriate.

If after these attempts, Biogen Idec is unable to reach the patient,then Biogen Idec will follow the Patient Discontinuation processoutlined in Section 3.7. Significant non-compliance with theserequirements on the part of the prescriber may result in de-enrollmentof the prescriber and forfeiture of the authorization to prescribeTYSABRI®, after review by the TYSABRI® Compliance Review Committee (SeeSection 10.3.2). Affected patients will be directed to other authorizedprescribers in the area; if this is not possible, then the affectedpatients could potentially be de-authorized as well. Similarly, apersistent pattern of non-compliance on the part of the infusion sitemay result in de-enrollment of the infusion site and forfeiture of theauthorization to administer TYSABRI®, after review by the ComplianceReview Committee (described in Section 10.1 and 10.3.2).

If the patient has discontinued TYSABRI®, Biogen Idec will follow thePatient Discontinuation process outlined in Section 3.7. Biogen Idecwill then contact the prescriber 6 months later to complete a TYSABRI®Discontinuation Questionnaire to obtain the final safety follow-up onthe patient (described in Section 6.8).

Consistent with the PI, the Sponsor recommends that TYSABRI® beadministered every 4 weeks (28 days). TYSABRI® clinical trials permitteddosing within +/−5 days of the 28-day dosing interval.

4.8 Follow-Up of Pre-Infusion Patient Checklist Findings

Biogen Idec intends to follow-up on certain findings on the Pre-InfusionPatient Checklists. When Biogen Idec receives a completed Pre-InfusionPatient Checklist, Biogen Idec will review the data on the Checklist.Biogen Idec will call the infusion site to follow-up on incomplete orillegible forms. The Sponsor will follow-up within two business days toobtain this information.

If Biogen Idec receives a checklist in which the infusion site did notprovide the Medication Guide, and/or confirm the patient's enrollmentstatus, and the patient was infused, Biogen Idec will send a fax to theinfusion site instructing the site of these requirements prior to everyinfusion. In addition, in other cases of infusion site non-compliance(e.g., the answer to Question 1, 2, 3, or 4 was YES, the patient wasinfused but the prescriber did not approve the infusion), Biogen Idecwill contact the site to re-enforce its TOUCH Prescribing Programobligations with respect to the Pre-Infusion Patient Checklist.

As discussed during the Advisory Committee meeting, Biogen Idec expectsthat a high proportion of submitted Pre-Infusion Patient Checklists willcontain reports of “worsening symptoms” that are in fact, MS-relatedsymptoms, including relapses. The Pre-Infusion Patient Checklist isdesigned to trigger prescriber consultation in the event that thepatient reports such symptoms and in turn, prescribers are required toreport any case of PML to Biogen Idec promptly. Therefore, Biogen Idecwill notify the prescriber in the event that the answer to Questions 1,2, 3, or 4 is YES and the form indicates that the infusion site did notnotify the prescriber. Under these circumstances, Biogen Idec willcontact the prescriber and inform him/her of the findings and recommendfurther evaluation, if justified (see Section 10.2.5). In addition, thechecklist prompts infusion personnel to refer to the previous checklistprior to an infusion. If the previous checklist notes that follow-upwith the prescriber was required, infusion site personnel must confirmauthorization from the prescriber was obtained prior to providing thecurrent infusion.

Because PML is a rare event and because neurological symptoms are commonin MS patients, it is likely that the Pre-Infusion Patient Checklistwill have a low “signal to noise” ratio with respect to worseningneurological symptoms indicative of PML. In light of this, Biogen Idecis proposing an aggressive approach to follow-up on a single missingPre-Infusion Patient Checklist, as a missing checklist may be morelikely to be indicative of a prolonged dose suspension in the setting ofPML or another serious adverse event (see Section 4.7).

5 Mandatory Enrollment of Central Pharmacies

Central pharmacies that dispense TYSABRI® to authorized infusion sitesmust also enroll in the TOUCH Prescribing Program. Note that centralpharmacies are distinct from specialty pharmacies described in Section2. Central pharmacies are located within a hospital, group practice, orinfusion site, and are affiliated with an infusion site (i.e., thecentral pharmacy stores product inventory and releases it to an infusionsite locally). Retail pharmacies and wholesalers are excluded fromholding and dispensing TYSABRI®.

5.1 Central Pharmacy Enrollment Form

Biogen Idec or Elan will provide training to central pharmacies byproviding the various TOUCH Prescribing Program educational materials,including the TOUCH Prescribing Program Slide Set and Inventory Log. Thecentral pharmacy will designate a person with appropriate authority tosign the Central Pharmacy Enrollment Form on behalf of the centralpharmacy. By signing the form, central pharmacies acknowledge thefollowing:

Central Pharmacy Acknowledgement

The central pharmacy acknowledges that:

-   -   A representative of Biogen Idec or Elan Pharmaceuticals, Inc.        has provided training and educational materials on the TOUCH        Prescribing Program    -   Central pharmacies may dispense TYSABRI® only to authorized        infusion sites    -   The TYSABRI® Inventory Tracking Log must be completed for every        dose of TYSABRI® dispensed to authorized infusion sites.        Inventory Tracking logs must be kept for at least 5 years from        the date of the final log entry.    -   I understand that, per the requirements of the TOUCH Prescribing        Program, this central pharmacy may be audited by the Food and        Drug Administration (FDA), Biogen Idec, Elan Pharmaceuticals,        Inc., and/or a third party designated by the FDA, Biogen Idec,        or Elan Pharmaceuticals, Inc.    -   Noncompliance with the requirements of the TOUCH Prescribing        Program may result in de-enrollment of the central pharmacy and        forfeiture of the authorization to dispense TYSABRI®

The completed and signed form must be faxed to Biogen Idec.

5.2 Central Pharmacy Enrollment Process

Biogen Idec will maintain the complete list of authorized centralpharmacies in the TOUCH database. As described in FIG. 6, thesepharmacies will be entered into the TOUCH database when Biogen Idecreceives a properly completed Central Pharmacy Enrollment Form. At thattime, a unique Site Authorization Number will be assigned to the centralpharmacy in the TOUCH database. Biogen Idec will fax the CentralPharmacy a Site Authorization Confirmation, which includes an SiteAuthorization Number, and a list of affiliated authorized infusionsites. This Site Authorization Number will be used by the centralpharmacy to order TYSABRI®. If a Central Pharmacy misplaces the SiteAuthorization Confirmation, they may call Biogen Idec at 1-800-456-2255and request a copy.

6. Systematic Tracking of All TYSABRI®-Treated Patients 6.1 TOUCHPrescribing Program Safety Surveillance Goals

The TOUCH Prescribing Program is designed to assess the incidence andrisk factors for PML and other serious OI with TYSABRI® treatment. Incontrast to the typical post-marketing surveillance model that relies onspontaneous reporting of adverse events to the manufacturer, Biogen Idecthrough the TOUCH Prescribing Program, will systematically follow andactively solicit information regarding the occurrence of PML and otherserious opportunistic infections through a variety of mechanisms onevery TYSABRI®-treated patient in the US. The TOUCH Prescribing Programwill seek to provide a complete denominator of TYSABRI®-treated patients(including person-years of exposure) and a complete numerator of any PMLor other serious OI that may occur. In addition, careful analysis of anycase of PML or other serious OI may provide insights into potential riskfactors for such events.

Thus, Biogen Idec will closely monitor the incidence, rate, andmorbidity and mortality of PML and other serious OI over time after there-introduction of TYSABRI® into the US market. Any clinicallysignificant change in the estimated risk of PML or other serious OI willtrigger a prompt discussion with the FDA and appropriate action.

6.2 Multimodality Safety Tracking for PML and Other Serious OI

The TOUCH Prescribing Program is intended to provide diligent safetysurveillance and systematic tracking of all patients treated withTYSABRI® for the occurrence of PML and other serious OI. Biogen Idecwill actively solicit information regarding the occurrence of PML andother serious OI through multiple methodologies.

-   -   Through monthly, real-time collection of Pre-Infusion Patient        Checklists, Biogen Idec will track TYSABRI® dosing on an        up-to-date, individual patient basis. Biogen Idec has proposed        an intensive diligence process to follow-up on missing        Pre-infusion Patient Checklists or on Pre-Infusion Patient        Checklists with findings (Section 4.7 and 4.8).    -   On the mandatory Prescriber/Patient Enrollment Form, prescribers        must attest to report to Biogen Idec any case of PML, other        serious OI, or death (Section 3.1).    -   On the mandatory Prescriber/Patient Enrollment Form, patients        must attest that they will report to their prescriber any new or        worsening symptoms that last several days, especially nervous        symptoms (Section 3.1). The Medication Guide also provides these        instructions to the patient. If the prescriber determines that        the symptoms are related to PML then the prescriber is obligated        to report the case to Biogen Idec.    -   The TOUCH Prescribing Program Overview will be disseminated to        healthcare professionals involved in TYSABRI® treatment and will        instruct them to report serious adverse events to Biogen Idec at        1-800-456-2255.    -   For additional diligence, Biogen Idec will actively query        prescribers every 6 months on each of their patients regarding        the occurrence of PML, other serious OI, or death using a        TYSABRI® Patient Status Report and Reauthorization        Questionnaire, described in Section 6.3. If a patient        discontinues TYSABRI® treatment, Biogen Idec will actively        follow-up on the status of such a patient as described in        Section 3.7 and 6.8, respectively.

Thus, Biogen Idec has multiple mechanisms, in addition to spontaneousreporting, to help assure that if PML or other serious OI occurs, BiogenIdec will be informed about it as soon as possible.

6.3 Description of TYSABRI® Patient Status Report and ReauthorizationQuestionnaire

The TYSABRI® Patient Status Report and Reauthorization Questionnairewill be sent to every prescriber for every patient every 6 months.

The purpose of this questionnaire is to ascertain the vital status ofthe patient and the occurrence of PML or other serious OI, and for theprescriber to reauthorize the patient to continue to receive TYSABRI®for the next 6 months. Specifically, prescribers will be asked whetherthe patient is still under their care, whether the patient is alive,whether the patient has a diagnosis of PML or has been hospitalized foran opportunistic infection. In addition, the Questionnaire will askwhether the patient is receiving or has received within the last 6months any immunomodulatory or immunosuppressant therapies, whether thepatient is currently or has received within the last 6 months anysystemic steroids, whether the patient has received intermittentsteroids within the last 6 months, and whether the prescriber isauthorizing the continuation of TYSABRI® treatment in this patient forthe next 6 months. Biogen Idec will fax the questionnaire to theprescriber who will be expected to complete and return it to Biogen Idecby fax or mail.

6.4 TYSABRI® Patient Status Report and Reauthorization QuestionnaireProcess

Biogen Idec will maintain the data from each TYSABRI® Patient StatusReport and Reauthorization Questionnaire in the TOUCH database. Asdescribed in FIG. 7, these data will be entered into the TOUCH databasewhenever Biogen Idec receives a TYSABRI® Patient Status Report andReauthorization Questionnaire. Biogen Idec will verify that the data arecomplete and accurate. If there is missing information on thequestionnaire, Biogen Idec will contact the prescriber to provide themissing information. If Biogen Idec does not receive the questionnairein a timely fashion from the prescriber, Biogen Idec has a diligenceprocess to obtain a completed questionnaire (described in Section 6.7).If a prescriber reports a case of PML, other serious OI, or death on thequestionnaire, Biogen Idec Drug Safety will rapidly contact theprescriber and diligently obtain more information on the case (describedin Section 7). Biogen Idec will report to FDA in an expedited basis(within 15 calendar days) all confirmed PML cases, as well as cases ofserious OI or death (described in Section 10.2.1).

The TYSABRI® Patient Status Report and Reauthorization Questionnairedata will be linked to the patient, infusion site and prescriber data inthe TOUCH database. A history of the TYSABRI® Patient Status Report andReauthorization Questionnaire data will be tracked for each patient andeach prescriber. In a later phase of the program, prescribers may havethe option of using a web-based system to directly enter theQuestionnaire data into the TOUCH database. This web-based capabilitymay simplify monitoring of compliance with the TOUCH PrescribingProgram.

6.5 Reauthorization Process for Every Patient Every 6 Months

The prescriber must reauthorize TYSABRI® use for the patient every 6months using the TYSABRI® Patient Status Report and ReauthorizationQuestionnaire. Note that all data fields on the questionnaire must becompleted and the answers appropriate (i.e., the prescriber has answeredQuestions A, B, C, and D as YES, YES, NO, and NO, respectively, asdescribed in Section 6.6). In addition, the prescriber must authorizethe continuation of TYSABRI® in order for the patient to continue toreceive TYSABRI® treatment.

An appropriately completed questionnaire is a requirement for thepatient to continue to receive TYSABRI® treatment. In order for theprescriber to be able to complete this questionnaire, the Sponsorexpects that the prescriber will have recently examined the patient. Byrequiring reauthorization for TYSABRI® use through the use of thisquestionnaire, Biogen Idec helps to facilitate close clinical follow-upof the patient by their prescriber, including patient-prescriber visitsevery 6 months. Upon reauthorization, a Notice of Patient Authorizationwill be sent to the prescriber and infusion site with the new patientauthorization period. Infusion site personnel will be prompted toconfirm that the patient is currently authorized prior to every infusionvia directions on the Pre-Infusion Patient Checklist.

If the prescriber does not reauthorize the continuation of TYSABRI®treatment, then Biogen Idec will follow the patient discontinuationprocess outlined in Section 3.7 Biogen Idec will then send theprescriber a final follow-up TYSABRI® Patient DiscontinuationQuestionnaire on this patient 6 months later, as described in Section6.7.

6.6 Follow-Up of Findings on the TYSABRI® Patient Status Report andReauthorization Questionnaires

Question A: Is this patient still under your care?

If the answer to this question is NO and the prescriber does not knowthe name of the new prescriber caring for the patient, then Biogen Idecwill contact the patient to determine whether the patient is stillreceiving TYSABRI® treatment and to obtain the name and contactinformation of the patient's new prescriber.

If the patient is still receiving TYSABRI® treatment but has changedprescribers, then Biogen Idec will remind the patient of his or herobligation to notify Biogen Idec upon changing prescribers, and willsend a Prescriber/Patient Enrollment Form to the new prescriber torequest completion and return to Biogen Idec. Then Biogen Idec will sendthe new prescriber a TYSABRI® Patient Status Report and ReauthorizationQuestionnaire to complete on this patient.

If the patient is no longer receiving TYSABRI® treatment, Biogen Idecwill follow the Patient Discontinuation process outlined in Section 3.7.Biogen Idec will contact the patient's current prescriber 6 months laterto complete a TYSABRI® Patient Discontinuation Questionnaire on thispatient.

Question B: Is the patient alive?

If the answer is NO, Biogen Idec Drug Safety will rapidly contact theprescriber and will diligently obtain detailed information on the case.The follow-up of death is described in Section 7.

Question C and D: Does the patient have a diagnosis of PML that you havenot already reported to Biogen Idec? Has the patient been hospitalizedfor an opportunistic infection that you have not already reported toBiogen Idec?

If the answer to either of these questions is YES or UNDERINVESTIGATION, Biogen Idec Drug Safety will rapidly contact theprescriber and will diligently obtain detailed information on the case.The follow-up of suspected PML and other serious OI is described inSection 7.

Question E: Is the patient currently or has the patient receivedintermittent courses of steroids for the treatment of MS relapse in theprevious 6 months? If YES, please indicate the number of coursesreceived.

These data can be used to characterize the pattern of intermittent useof steroids in the TOUCH prescribing program population.

Question F: Is the patient currently or has the patient received anyimmunomodulatory or immunosuppressant therapies in the previous 6months? If YES, please indicate the type of therapy (AVONEX, Betaseron,Copaxone, Rebif, Novantrone, Azathioprine, Methotrexate, Mycophenolate,Cyclophosmamide, Chronic Systemic Steroids or Other immunomodulatory orimmunosuppressive therapy) and number of months of use.

If the answer to this question is YES, Biogen Idec will send theprescribing physician a letter warning them that TYSABRI® is indicatedfor use as a monotherapy and warning against the use of TYSABRI® incombination with other immunosuppressants or immunomodulators.

Question G: If the patient is still under your care, do you authorizethe continuation of TYSABRI® treatment for the next 6 months for thispatient?

For the patient to continue to receive TYSABRI®, the answer to questionG must be YES. (Of course, the patient must not have or be underinvestigation for PML or serious OI to continue TYSABRI® treatment).

If the Answer to G is NO, then Biogen Idec will follow the PatientDiscontinuation process outlined in Section 3.7. Biogen Idec will thensend the prescriber a TYSABRI® Patient Discontinuation Questionnaire 6months later to ascertain the status of the patient.

6.7 Diligence with Follow-Up of Missing TYSABRI® Patient Status Reportand Reauthorization Questionnaires

Biogen Idec will make diligent efforts to obtain a completed TYSABRI®Patient Status Report and Reauthorization Questionnaire from theprescriber on each authorized patient every 6 months.

For every patient every 6 months, Biogen Idec will send the prescriberthe questionnaire approximately 5 months after the first dose or 5months after the most recent previous TYSABRI® Patient Status Report andReauthorization Questionnaire (which ever is later). If there is noresponse, then Biogen Idec will send the prescriber a second copy of thequestionnaire. If after these attempts the prescriber does not providethis information, Biogen Idec will contact the prescriber by telephoneup to 3 times. If the prescriber has still not completed thequestionnaire, then Biogen Idec will make up to 2 telephone contactsdirectly to the patient. The purpose of these patient contacts is todetermine the vital status of the patient, whether the patient is onTYSABRI® treatment, whether the patient has been hospitalized, andremind the patient to contact their prescriber. If the patient has diedor has been hospitalized, the Biogen Idec Drug Safety will rapidly anddiligently investigate the case.

If Biogen Idec cannot reach the patient despite these attempts, BiogenIdec will follow the Patient Discontinuation process outlined in Section3.7. A significant pattern of non-compliance with these requirements onthe part of the prescriber may result in de-enrollment of the prescriberand forfeiture to prescribe TYSABRI®, upon review by the ComplianceReview Committee. Affected patients will be directed to other authorizedprescribers in the area (see Section 10.3.2).

If the patient has changed prescribers, then Biogen Idec will contactthe new prescriber to request completion and submission of a newPrescriber/Patient Enrollment Form to Biogen Idec. Then, Biogen Idecwill send the new prescriber a TYSABRI® Patient Status Report andReauthorization Questionnaire to complete on the patient and send backto Biogen Idec.

6.8 TYSABRI® Patient Discontinuation Questionnaire: Follow-Up forPatients Who Discontinue TYSABRI® Treatment

Biogen Idec has designed several mechanisms to determine whether apatient may have discontinued TYSABRI® treatment. These include:

-   -   A prescriber may complete, and fax in a Patient Discontinuation        Notification Form. This form will be provided to prescribers in        the Enrollment Kit.    -   Through monthly collection of Pre-Infusion Patient Checklists,        Biogen Idec will track TYSABRI® dosing on an individual patient        basis. By diligently following-up on any missing Pre-infusion        Patient Checklists, Biogen will identify any patient who has        discontinued TYSABRI® treatment (Section 4.7 and 4.8).    -   Biogen Idec will identify patient discontinuations through the        TYSABRI® Patient Status Report and Reauthorization Questionnaire        (e.g., if the prescriber does not authorize the continuation of        TYSABRI® dosing in the patient).    -   Biogen Idec may also confirm patient discontinuations through        spontaneous reporting by the patient, prescriber, or infusion        site.

If a patient discontinues TYSABRI® treatment, Biogen Idec will followthe Patient Discontinuation process outlined in Section 3.7. Physicianswill be expected to complete a TYSABRI® Patient DiscontinuationQuestionnaire both at the time that the patient discontinues TYSABRI® aswell as 6 months after their last dose. At both these timepoints, theprescriber will be sent a TYSABRI® Patient Discontinuation Questionnaireto complete and send back to Biogen Idec. This questionnaire queries theprescriber regarding the vital status of the patient, and the occurrenceof PML or other serious OI.

The same diligence process described in Section 6.7 will be applied tofacilitate the receipt of the completed TYSABRI® Patient DiscontinuationQuestionnaire. In addition, as described in Section 6.6, if there is areport of patient death, PML, or other serious OI on the questionnaire,then Biogen Idec Drug Safety will rapidly contact the prescriber andwill diligently obtain detailed information on the case.

6.9 TOUCH Prescribing Program: Summary of Patient Data Collection

At the heart of the TOUCH Prescribing Program is an integrated,computerized, validated database that captures enrollment, patienttracking, and drug distribution data, as presented in FIG. 8.

Biogen Idec will collect the following data in the TOUCH PrescribingProgram:

Prescriber/Patient Enrollment Form

The Prescriber/Patient Enrollment Form will be used to collect thefollowing data on each patient:

-   -   patient's name, contact information, and social security number    -   date of birth    -   gender    -   signed prescriber acknowledgement    -   signed patient acknowledgement    -   name of the most recent MS therapy    -   duration of most recent MS therapy    -   any prior TYSABRI® treatment    -   infusion site information    -   TYSABRI® prescription

Monthly Pre-Infusion Patient Checklist

The following data will be collected on each Pre-Infusion PatientChecklist:

-   -   Dosing information, i.e., whether dose was administered, date of        dosing    -   Patient receipt of Medication Guide    -   Patient report of worsening neurological symptoms lasting        several days    -   Patient report of new medical conditions that could compromise        immune function    -   Patient report of concomitant use of antineoplastic,        immunosuppressant or immunomodulatory agents    -   Patient report of concomitant steroid use    -   Prescriber consultation in event of findings on checklist;        documentation of authorization to infuse TYSABRI® was received    -   Next scheduled infusion date (if known)

TYSABRI® Patient Status Report and Reauthorization and PatientDiscontinuation Questionnaires

The following data will be collected on these questionnaires:

-   -   Treating prescriber    -   Vital Status    -   Occurrence of PML    -   Occurrence of hospitalization for an opportunistic infection    -   Prescriber authorization to continue TYSABRI® (Patient        Reauthorization Questionnaire only)    -   Treatment with any concurrent immunomodulatory or        immunosuppressant therapies or chronic systemic corticosteroids        including number of months received (Patient Reauthorization        Questionnaire only)    -   Treatment with intermittent corticosteroids, including number of        courses received (Patient Reauthorization Questionnaire only)

TYSABRI® Distribution Data:

-   -   Central Distributor information: unique identifier, name,        invoice number, location shipped from    -   SPP information: unique identifier, name, location shipped from    -   Shipment information: quantity shipped, quantity returned, date    -   Ship-to information: identifier, name, address, class of trade    -   Shipment Authorization code: as obtained from TOUCH database for        each shipment

In addition to data above, Biogen Idec will collect the date of patientdiscontinuation from TYSABRI® treatment (see Section 6.8), as well asdata collected through the course of diligence efforts (e.g., missingPre-Infusion Patient Checklists, see Section 4.7). Note that diligenceefforts in response to Pre-Infusion Patient Checklists will becoordinated with diligence efforts in response to Patient Status andReauthorization and Discontinuation Questionnaires.

Finally, Biogen Idec will collect adverse events reported through theTOUCH Prescribing Program. These adverse events, whether reported by apatient, prescriber, or other person, will be entered and tracked inBiogen Idec's Drug Safety's Global Database (Oracle AERS). Reporting ofpre-infusion patient checklist data will be handled consistently withsection 10.2.5.

7 Special Assessments for PML, Other Serious OI, and Death

Biogen Idec Drug Safety will rapidly, diligently, and actively seek, andfollow up on, all relevant details and source information of each caseof PML, serious OI, or death, both those reported spontaneously andthose reported through the Patient Status and Reauthorization andDiscontinuation Questionnaires, to enable adequate assessment of thediagnosis, the course of the event, and potential predisposing factors.Biogen Idec Drug Safety will promptly contact the prescriber to requestcomplete clinical details on each case, as well as submission ofrelevant source documentation (e.g., pathology results, microbiologyresults), potential predisposing factors (e.g., prior and concurrenttherapies, underlying co-morbidities), clinical course and outcome.

Specifically, any report of PML will be evaluated in the followingmanner:

-   -   Biogen Idec will rapidly attempt to contact the prescriber to        obtain detailed information about the patient, using a        PML-specific questionnaire. Biogen Idec will request full        clinical details as well as submission of source documentation        (such as clinical findings, MRI, and CSF JC viral DNA results).    -   A case of PML will be considered confirmed based on pre-defined        criteria that have been developed in collaboration with external        independent experts. Specifically, a case will be considered        confirmed by the presence of JC viral DNA in either the        cerebrospinal fluid (CSF) or brain biopsy, in the appropriate        clinical and MRI setting.    -   If the diagnosis of PML is indeterminate, the Biogen Idec will        submit the source documentation on the case to an external PML        expert for an opinion of the diagnosis.    -   Finally, a qualitative analysis of the case will be performed to        identify any potential risk factors for PML development (e.g.,        prior or concomitant therapies, underlying co-morbidities, etc).

Similar diligence will be exercised in the investigation of any reportof serious opportunistic infection or death of any cause. If a patienthas died, the death certificate will be obtained on the patient. If thepatient was hospitalized, the patient's hospital records will berequested. Finally, the National Death Index will be queried toascertain the vital status of any patient lost to follow-up (see Section10.2.6).

For the purpose of expedited reporting, a serious OI is defined as aninfection due to an organism that generally does not cause disease, orcauses only mild or self-limited disease, in people with normallyfunctioning immune systems, but causes more significant disease inpeople with impaired immunity. These infections are frequently severe,prolonged or disseminated. Examples include esophageal candidiasis,systemic fungal infections, pneumocystis carinii pneumonia,mycobacterial infections (including both pulmonary and extra-pulmonarytuberculosis), chronic intestinal cryptosporidiosis, and disseminatedviral infections (such as disseminated herpes or cytomegalovirusinfections).

For any adverse event of special interest such as PML, other serious OI,or death, Biogen Idec Drug Safety will obtain the patient's exposure toTYSABRI® from the TOUCH database. In addition, Biogen Idec Drug Safetywill request that the reporter provide the patient's exposure history toTYSABRI® (if any) prior to the patient's enrollment into the TOUCHPrescribing Program, including any prior commercial or clinical trialexposure, the number of doses, and the approximate dates. If such apatient had been previously exposed to TYSABRI® in a clinical trial,Biogen Idec Drug Safety would obtain that patient's TYSABRI® exposurefrom the clinical trial database (assuming that the reporter is able toprovide the patient's name, date of birth, and the name of theinvestigator who previously authorized that patient into a TYSABRI®clinical trial or the location of the investigational site). Thus,Biogen Idec will attempt to ascertain the patient's total exposure toTYSABRI®, both within the TOUCH Prescribing Program and any previousexposure in clinical trials or commercially. This will facilitateanalysis of the relationship, if any, between adverse events of interestand duration of TYSABRI® exposure. These adverse events will be enteredand tracked in Biogen Idec Drug Safety's Global Safety Database (OracleAERS).

Although occurrence of PML would be considered an “expected” event basedon 21 C.F.R. 600.80 and the proposed revised Package Insert, Biogen Idecwill nevertheless report all cases with a confirmed diagnosis of PML tothe FDA on an expedited basis, i.e., within 15 calendar days of receiptof the case. In addition, other serious OI or death of any cause will bereported to the FDA on an expedited basis.

More details on the proposed reporting plan for PML, other serious OIand death are provided in Section 10.2.1.

8 Risk Minimization Tools 8.1 Tools for Prescribers, Patients, InfusionSites, and Central Pharmacies

Biogen Idec sought feedback from neurologists, infusion sites, infusionnurses, central pharmacies and MS patients to develop materials thatwould be useful, effective, and practical for managing the risk of PML.Based upon this feedback, Biogen Idec has developed a number of toolsthat will educate healthcare providers, and thus their patients, aboutthe potential risk for, and consequences of, PML with TYSABRI®treatment. Biogen Idec will use these materials, all subject to FDAreview and approval, in educating healthcare providers, and thuspatients, of the known risks and potential benefits of TYSABRI®treatment. These tools will be distributed directly to the infusionsites and prescribers with subsequent dissemination to patients.Patients and healthcare providers can also access up-to-date informationat Biogen Idec's website, TYSABRI.com, and through a toll-freephone-line to Biogen Idec's call center. Distribution of enrollmentforms will be controlled and available only from Biogen Idec and Elandirectly. Materials that are essential to implementation of the riskmanagement plan are listed in Table 2.

TABLE 2 RiskMAP Materials Material Brief Description Patient TheMedication Guide describes the known risks of Medication TYSABRI ® inpatient-oriented language. The Guide Medication Guide will accompany thepackage insert. In addition, the Medication Guide will be shippeddirectly to infusion sites and provided prior to every infusion to everypatient. Large-Font Large-font version of FDA-approved labeling, toVersions of facilitate readability and functionality of Patient thisinformation. Medication Guide and Full Prescribing Information TOUCHPowerPoint presentation to provide education Prescribing necessary toexecute TOUCH Prescribing Program Program Education Slide set TYSABRI ®PowerPoint presentation that includes clinical and TOUCH data and anoverview of the TOUCH Prescribing Prescribing Program elements, intendedfor physicians Program and patients (2 sections) Slide set TOUCH Generaldescription of the TYSABRI ® risk Prescribing management programoutlining responsibilities for Program prescribers, infusion sites,central pharmacies, Overview and patients. Prescriber/ Form to be signedby all patients and prescribers for Patient enrollment into the TOUCHPrescribing Program. Enrollment Form Infusion Site Form to be signed byinfusion sites for enrollment Enrollment into the TOUCH PrescribingProgram and to obtain Form designation as an authorized infusion site.Only authorized infusion sites are eligible to receive TYSABRI ®shipments. Central Form to be signed by central pharmacies for Pharmacyenrollment into the TOUCH Prescribing Program and to Enrollment obtaindesignation as an authorized central pharmacy. Form Only authorizedcentral pharmacies are eligible to receive TYSABRI ® shipments and maydispense TYSABRI ® only to authorized infusion sites within theirorganization/institution. TYSABRI ® Tracking log required for use bycentral pharmacies to Inventory document dispensing of TYSABRI ® toauthorized Tracking infusion sites associated to a central pharmacy LogPre-infusion Pre-infusion Patient Checklist to be used prior to eachPatient infusion for every patient on TYSABRI ®. Checklist Checklistmust be submitted to Biogen Idec upon completion. Patient Status Formthat must be filled out every 6 months Report and to obtain patientstatus and enable Re- prescriber reauthorization of the patient inauthorization the TOUCH Program Questionnaire Patient A form that may beused by prescribers to discontinue a Dis- patient and de-enroll themfrom the TOUCH Prescribing continuation Program. Notification FormPatient This form will be provided to prescribers when a patient Dis-discontinues TYSABRI ® treatment and 6 months after continuationdiscontinuation. Questionnaire TOUCH A folder provided to potentialprescribers that contains Enrollment approved TOUCH Materials (listedabove) and outlines Kit specific responsibilities of each of the partiesinvolved in the TOUCH Prescribing Program. Dear Doctor Communication toneurologists containing important Letter safety information regardingreintroduction of TYSABRI ® Dear Patient Communication to patients whohave Letter expressed an interest in receiving updates regardingTYSABRI ®, containing important safety information regardingreintroduction of TYSABRI ® Patient Brochure designed to assist patientsconsidering starting Getting treatment with TYSABRI ®. Contains summaryStarted information on the known risks and potential Brochure benefitsof therapy, in addition to an overview of TOUCH Requirements. HealthcareDesigned for use in the infusion-setting. Provides Professionalpractical step-by-step considerations for appropriate Infusion infusionof TYSABRI ® and reinforcement of Guide TOUCH requirements. TYSABRI.Website designed to disseminate approved labeling com information forTYSABRI ® and an overview of TOUCH Program requirements. Guidance forDocument provides guidance to healthcare professionals Evaluation whenundertaking the assessment and management of New of new or worseningneurologic Neurologic symptoms in multiple sclerosis (MS) Symptoms inpatients treated with TYSABRI ®. Patients Receiving TYSABRI ®(natalizumab) Additional Biogen Idec will support various otherinitiatives to Education provide educational materials about the PMLrisk and appropriate-use conditions for TYSABRI ®, to neurologists andinfusion nurses for use with MS patients. All neurologists in Biogenldec's database, including prescribers who have completed and submitteda Prescriber/Patient Enrollment Form, will receive periodic educationalmailings. Prescribers will be expected to share this information withtheir patients. These documents will be pre-cleared with DDMAC. Atoll-free help-line will provide prescribers and nurses access to healthcare professionals in Biogen Idec's medical information department whocan answer questions related to TYSABRI ®. Biogen Idec will supporteducational initiatives through the National MS Society (NMSS) InfusionNurse Society (INS), International Organization for MS Nurses (IOMSN)and will facilitate the generation and dissemination of medicalinformation on PML and TYSABRI ® through media such as review articles,seminars, and Continuing Medical Education (CME) programs directed atneurologists and infusion nurses.

9 Additional Studies 9.1 TYSABRI® Global Observational Program in Safety(TYGRIS)

Biogen Idec proposes that a large subset of patients in the TOUCHPrescribing Program also enroll into a voluntary observational studycalled the TYSABRI® Global Observational Program in Safety (TYGRIS).

TYGRIS will enroll approximately 5,000 patients worldwide, of whichapproximately 3,000 patients will be authorized in the US, and thesepatients will be systematically followed for up to 5 years. Note that inthe US, only prescribers and patients already authorized in themandatory TOUCH Prescribing Program will be eligible to participate inthe voluntary TYGRIS study. The objectives of this observational studyare to determine the incidence and pattern of serious infections andmalignancies, as well as the overall safety profile of TYSABRI® in MSpatients with long-term use in clinical practice.

Whereas the TOUCH Prescribing Program is focused on determining theincidence of PML and other serious OI, TYGRIS will evaluate newlyemerging risks, if any, with TYSABRI® monotherapy treatment in MSpatients. While the safety profile of TYSABRI® in clinical trials hasbeen well-characterized regarding the incidence and nature of commonserious adverse events over a 2-year period, the incidence of rareevents, the safety profile beyond 2 years, and the safety profile inclinical practice will be better characterized in this study. Forexample, while the clinical trial data on malignancy is reassuring, itwould be important to evaluate the incidence of malignancy over thelonger term because malignancies can be long-latency events. In additionto the very targeted data collection in the TOUCH Prescribing Program,data collection in an observational study such as TYGRIS allows BiogenIdec to evaluate a broader range of as yet unknown issues as wellunexpected safety findings with TYSABRI® use in the clinical practicesetting.

Baseline demographic data have been collected on all patients on thePrescriber/Patient Enrollment Form for the TOUCH Prescribing Program, asdescribed in Section 6.9. For patients also participating in TYGRIS,additional baseline demographics will be collected, including pastmedical history (including history of serious infections, malignancies,other serious adverse events, and pregnancy status, if applicable), MShistory (including past or current treatments), prior use and durationof immunomodulatory, antineoplastic, or immunosuppressive agents, andprior detailed use of TYSABRI®.

Thereafter, prescribers participating in TYGRIS are instructed to reportany serious adverse event to Biogen Idec within 24 hours of the sitebecoming aware of the event. Participating prescribers will also becontacted every 6 months and will be asked to provide any seriousadverse events that they have not yet reported as well as the patients'exposure to any concomitant antineoplastic, immunomodulatory orimmunosuppressant therapies, or systemic corticosteroids. The RiskMAPdiscourages concurrent use of TYSABRI® with such therapies; thereforeBiogen Idec anticipates that there should be little or no use of suchtherapies concurrently with TYSABRI®. It should also be noted thatparticipating prescribers in TYGRIS in the US, like all prescribersauthorized in the TOUCH Prescribing Program, must also reauthorizeTYSABRI® dosing on every patient every 6 months.

Biogen Idec intends to recruit a large number of prescribers(approximately 250 in the US) from both private and hospital-basedpractices. Prescribers who will employ a central Institutional ReviewBoard (IRB) for the study will be given preference for participation. Inthis way, Biogen Idec will strive to enroll into TYGRIS a patientpopulation that is representative of patients treated in a clinicalpractice setting.

A sample size of 5000 MS patients will be enrolled and followed for 5years whether continuing on TYSABRI® or not. Assuming a 20%discontinuation rate from TYSABRI® at the beginning of year 2 and a 10%annual discontinuation rate from TYSABRI® thereafter, it is estimatedthat 18,700 patient-years of TYSABRI® exposure will be completed in thisstudy. Assuming approximately 1000 patient-years lost to follow-up, atotal of 24,000 patient-years of follow-up will accrue. This studydesign will allow the detection of important rare serious adversereactions that occur with an incidence of 0.06% with a 95% probabilityand an incidence of 0.05% with 92% probability.

9.2 Pregnancy Registry

Biogen Idec will establish a Pregnancy Registry in the US to determinethe safety of TYSABRI® in pregnant patients. Approximately 300TYSABRI®-exposed pregnant MS patients will be authorized. The primaryobjective of this study will be to evaluate any pattern or increase inbirth defects in children of women with multiple sclerosis who wereexposed to TYSABRI® at any time within 3 months prior to conception, orat any time during pregnancy, where the outcome of the pregnancy isunknown at the time of enrollment. The secondary objectives will be todescriptively evaluate the following outcomes in pregnant women exposedto natalizumab: live born infants, fetal loss (stillbirths,elective/spontaneous abortions), and gestational age, body weight,gender, head circumference, and length of child. Biogen Idec committedto this study as part of the post-approval commitments for the initialBLA.

9.3 Safety of Re-Exposure to TYSABRI®

In order to evaluate the safety of TYSABRI® with re-exposure after aninterval without treatment, Biogen Idec will conduct two multi-national,open-label studies. Approximately 1,500 patients with MS who previouslyreceived TYSABRI® treatment during their participation in clinicalstudies will be authorized.

9.4 Effect of TYSABRI® on Immune Function

Biogen Idec will conduct a study in approximately 40 MS patients toevaluate the effect of TYSABRI® on humoral and cellular immunity torecall and neo-antigens. Both cellular (ex vivo proliferation responses)and humoral (specific serum immunoglobulin) immune responses to recallvaccine antigens (e.g., tetanus and pneumovax) and naïve antigens (KLH)will be studied with or without natalizumab treatment. Data from thisstudy may provide information into potential immunological risk factorsfor PML with TYSABRI® treatment. Biogen Idec committed to this study aspart of the post-approval commitments to the initial SLA.

9.5 Non-Clinical Studies

A direct animal model of JC virus associated PML has not been described.Biogen Idec will initiate specific in vitro studies to investigate theeffects of natalizumab interaction with specific cellular targets andfunctions with respect to JC virus infection and replication. Inaddition, the effects of short-term alpha 4-integrin inhibition inrodent and guinea pig experimental autoimmune encephalomyelitis will beevaluated, specifically with respect to effects on immune function.These non-clinical studies, while exploratory, may provide insights intopotential immunological risk factors for PML with TYSABRI® therapy.

10 Evaluation/Quality Plan

Biogen Idec and Elan are committed to evaluating the effectiveness ofthe TYSABRI® RiskMAP and reporting the results on a quarterly basis tothe FDA. Each submission will include two major datasets: (1) HealthOutcomes Data (e.g., PML rate, overall safety), and (2) Systems/ProcessData, Quality and Compliance Metrics. The specific type and frequency ofdata that the Sponsor will submit to the FDA is outlined in detail inthis Section. A more detailed description of the systems and compliancedata being monitored and evaluated can be found in the Quality Plan.

A key feature of the Sponsor's RiskMAP evaluation process will beinternal senior management review of these data by a multi-disciplinaryTYSABRI® Risk Management Review Committee.

The Evaluation/Quality Plan will allow Biogen Idec to assess theeffectiveness of the RiskMAP in an ongoing fashion and to improve theplan, as necessary.

10.1 TYSABRI® Risk Management Review Committee

A multi-disciplinary TYSABRI® Risk Management Review Committee composedof senior representatives from Biogen Idec and Elan's Drug Safety,Clinical, Commercial, Regulatory, Legal, and Quality Departments will beformed. This Committee will evaluate the effectiveness of the riskmanagement plan on a quarterly basis, both from a health outcomesperspective (e.g., PML rate, overall safety) as well from asystems/process perspective (e.g., Quality Plan execution andsystems/compliance metrics). This Committee will also make decisionsregarding any major corrective actions to the RiskMAP, if needed. Thedecisions and outcomes of this Committee will be included in thequarterly reports to the FDA.

10.1.1 TYSABRI® Safety Review Committee

Biogen Idec and Elan will create a joint TYSABRI® Safety ReviewCommittee chaired by Drug Safety and Risk Management of Biogen Idec andcomposed of a cross-functional team from both Biogen Idec and Elan. ThePurpose of this Committee is to review TYSABRI® safety data and todetermine appropriate corrective actions, if needed. The Committee willmeet on a regular basis to review the data discussed in Section 10.2 ofthis document.

10.1.2 TYSABRI® Compliance Review Committee

Biogen Idec and Elan will create a joint TYSABRI® Compliance ReviewCommittee chaired by Quality at Biogen Idec and composed of across-functional team from both Biogen Idec and Elan. The Purpose ofthis Committee is to facilitate RiskMAP compliance and effectiveexecution of the Quality Plan. The Committee will meet on a monthlybasis, and as needed, to review results from monitoring of operationalprocesses, distribution data, audit data and any emerging trends or outof tolerance levels. In addition, this committee will determine theappropriate corrective action to be taken to address non-compliance andto ensure continuous improvement for any of the RiskMAP activities.

10.2 Health Outcomes Evaluation

The following results will be provided to the FDA, according to Table 3.

TABLE 3 Health Outcomes Evaluation: Metrics and Methods. Expected dateafter re-introduction Evaluation into Metric method US market BaselineDemographics in TOUCH TOUCH Quarterly for Prescribing Program (i.e.,summary Prescribing the first year, statistics on age, gender, Program:biannually (every relapsing MS diagnosis, most Enrollment 6 months) forrecent MS therapy, any prior Form 2 years, then TYSABRI ® exposure)annually thereafter Proportion of patients who have TOUCH Quarterly forthe received concurrent immuno- Prescribing first year, modulatory orimmunosuppressant Program: biannually agents or chronic systemiccortico- Patient (every 6 steroids and months of exposure Status andmonths) for to such therapies** Proportion of Re- 2 years, then patientswho have received authorization annually intermittent corticosteroidsForm thereafter and number of courses received Baseline Demographics inTYGRIS TYGRIS Quarterly for (i.e., summary statistics as above, as Studythe first year, well as past MS history, all prior biannuallyimmunomodulatory and (every immunosuppressant therapies, past 6 months)for medical history, past serious 2 years, theninfections/malignancies/other SAEs) annually thereafter Proportion ofpatients concurrently TYGRIS Quarterly for treated with immunomodulatoryor Study the first immunosuppressant agents** year, biannually (every 6months) for 2 years, then annually thereafter Listings and casenarratives for all TOUCH Quarterly for confirmed and suspected PMLcases, Prescribing the first other serious OI, and deaths; Program year,biannually Estimate of PML and other serious (every 6 months) OIincidence and rate (based on for 2 years, number of confirmed cases per1000 then annually persons/person-years of exposure); thereafterqualitative analysis of risk factors for PML and other serious OI basedon review of confirmed cases Listing, incidence, and rate TOUCHQuarterly for of patients who discontinued Prescribing the firstTYSABRI ® Program year, biannually (every 6 months) for 2 years, thenannually thereafter Post-Marketing Safety Adverse PSUR* every 3 Eventsmonths for first 2 collected years, then semi- from the annually TOUCHPrescribing Program Incidence and pattern of serious TYGRIS YearlyInterim infections and malignancies Study Clinical Study Reports Notethat related SAEs from TYGRIS will be provided in the PSUR*. Results ofNational Death National Every 12 months Index Search Death Index Safetywith Re-Treatment IND Annual Annually (final Report Clinical Study forReport when Re-Dosing studies Studies completed) Note that related SAEsfrom these studies will be provided in the PSUR*. TYSABRI ® impact onimmune IND Annual Annually (as well function Report as final Clinicalfor Study Report Immune when studies Function/ completed) Vaccine Notethat related Study SAEs from these studies will be provided in thePSUR*. TYSABRI ® impact on Pregnancy Analyses will be pregnancy outcomesRegistry provided in the PSUR*. *PSUR = Periodic Safety Update Report,please see Section 10.2.4 **Consistent with the PI, TYSABRI ® is notordinarily recommended in patients who are receiving chronicimmunosuppressant or immunomodulatory therapy; therefore Biogen Idecanticipates little or no reported use of TYSABRI ® under thesecircumstances in the TOUCH Prescribing Program.

10.2.1 Expedited Reporting of Events of Interest (e.g., PML, Serious OI,Death) in the TOUCH Prescribing Program

Following the commercial re-introduction of TYSABRI® into the US market,the Sponsor is proposing the following paradigm for the reporting ofadverse events in the TOUCH Prescribing Program.

All spontaneous and solicited adverse event reports from anypost-marketing source will be reported as per 21 CFR 600.80(Post-marketing Reporting of Adverse Experiences).

In addition, the following describes the process for expedited reportingfor key safety events from any source in the post-marketing space:

Progressive Multifocal Leukoencephalopathy:

The Sponsor will diligently follow-up on any report of possible PML, andwill expedite to FDA within 15 calendar days any PML case consideredconfirmed by the presence of JC viral DNA in the CSF or brain biopsy inthe appropriate clinical and MRI setting. All other possible cases, notconfirmed by the presence of JC viral DNA in the CSF or brain biopsy,will be reported quarterly in the Periodic Report (Section 10.2.4).

Other Serious Opportunistic Infections and Deaths of Any Cause:

The Sponsor will diligently follow-up on and provide expedited reportingto FDA within 15 calendar days of receiving any report of other seriousopportunistic infections or deaths of any cause. The definition forserious OI is provided in Section 7.

10.2.2 Expedited Reporting of Events of Interest from TYSABRI® Studiesand Clinical Trials

The Sponsor is proposing the following paradigm for the reporting ofadverse events in TYSABRI® studies and clinical trials (i.e., TYGRIS andRe-Dosing Studies).

In TYSABRI® studies and clinical trials, all serious unexpected andrelated events will be reported in an expedited fashion to the Agency asper 21 CFR 312.32 (IND Safety Reports).

In addition, the following describes the process for expedited reportingfor key safety events from any TYSABRI® studies or clinical trials:

Progressive Multifocal Leukoencephalopathy:

The Sponsor will diligently follow-up on any report of possible PML, andwill expedite to FDA within 15 calendar days any PML case consideredconfirmed by the presence of JC viral DNA in the CSF or brain biopsy inthe appropriate clinical and MRI setting, regardless of the investigatorcausality assessment.

Other Serious Opportunistic Infections:

The Sponsor will diligently follow-up on and expedite to FDA within 15calendar days of receiving any report of other serious opportunisticinfections, regardless of the investigator causality assessment. Thedefinition for serious OI is provided in Section 7.

Deaths of Any Cause:

The Sponsor will diligently follow-up on any report of death andexpedite to FDA within 15 calendar days any report of death that isunexpected and considered related according to the investigator.However, if the death is due to a confirmed case of PML or a serious OI,then the Sponsor will expedite within 15 calendar days regardless of theinvestigator causality assessment.

10.2.3 PML and Other Serious OI Incidence, Rate and Risk Factors

Biogen Idec will closely monitor the incidence, rate, and morbidity andmortality of PML and other serious OI over time after there-introduction of TYSABRI® into the US market. Any clinicallysignificant change in the risk of PML or other serious OI will trigger aprompt discussion with the FDA and appropriate action.

In addition, cases of confirmed PML and other serious OI will betabulated every 3 months after re-introduction and provided to the FDAexpressed as:

-   -   Number of cases per estimate of total population exposed        (cases/persons exposed)    -   Number of cases per estimate of person-years of TYSABRI®        exposure (cases/person-years exposure)    -   A qualitative analysis of any confirmed cases of PML and other        serious OI will be made to identify any potential risk factors        (e.g., prior or concomitant therapies, underlying        co-morbidities, etc).

The person-years of exposure will be derived from the total number ofpatients treated with TYSABRI® in the TOUCH Prescribing Program and fromthe total number of TYSABRI® infusion administered (the latter will beobtained from the submitted Pre-Infusion Patient Checklist data).

10.2.4 Periodic Reports

Biogen Idec and Elan are proposing to substitute the Periodic AdverseEvent Report (PAER) (as per 21 CFR 600.80 (c)(2)), with theinternational Periodic Safety

Update Report (PSUR) (as per the International Conference onHarmonisation (ICH) guideline designated as ICH-E2C and published in theFederal Register on 19 May 1997).

This PSUR will be submitted quarterly for the first 2 years afterre-introduction of TYSABRI®, and semi-annually thereafter.

10.2.5 Reporting of Pre-Infusion Patient Checklist Data

Biogen Idec will collect Pre-Infusion Patient Checklists to monitorinfusion site compliance with this important requirement and to trackthe dosing of TYSABRI® on an individual patient basis. As discussed atthe Advisory Committee meeting, Biogen Idec expects that thesechecklists, collectively, will contain an extremely high prevalence ofreports of “worsening symptoms” that are, in fact, MS symptoms,including relapses. The Pre-Infusion Checklist is designed to triggerfurther follow-up (i.e., neurological consultation) under thesescircumstances, and prescribers are required to report any cases of PMLto Biogen Idec. Thus, Biogen Idec does not intend to report all cases of“continuously worsening symptoms” received in monthly Pre-InfusionPatient Checklists as adverse drug experiences under 21 C.F.R. 600.80.Instead, Biogen Idec will report all confirmed cases of PML, as well asserious opportunistic infections and deaths on an expedited basis.

10.2.6 Results of National Death Index Search

The National Death Index will be queried to ascertain the vital statusof any patient lost to follow-up. The National Death Index provides amatch with identifiers for a person who has died, the State of death,and the death certificate number. Then Biogen Idec will request thedeath certificates from the State Health Department. Recognizing thatthere is a lag time of approximately 18 months between patient death andthe updating of records in the National Death Index, the results ofthese queries will be provided to the FDA every 12 months aftercommercial re-introduction.

10.3 Systems/Process, Quality and Compliance Metrics

The following results will be provided to the FDA, according to Table 4.

TABLE 4 Systems and Processes: Metrics and Methods Expected MetricEvaluation method Date Prescriber knowledge and behavior Prescribersurvey Every 6 regarding TYSABRI ® and PML months Infusion nurseknowledge Infusion nurse Every 6 and behavior regarding survey monthsTYSABRI ® and PML Availability and use of tools at Prescriber surveyEvery 6 infusion sites and prescriber offices and infusion months nursesurvey Percentage of vials shipped to Distribution data Quarterly forauthorized infusion sites and the first year, central pharmaciesbiannually (every 6 months) for 2 years, then annually thereafter Numberof authorized patients, Enrollment Forms Quarterly for prescribers,infusion sites, central the first year, pharmacies biannually (every 6months) for 2 years, then annually thereafter Number of infusionsadministered Pre-Infusion Patient Quarterly for Checklists and Phone thefirst year, calls to Infusions biannually Sites (every 6 months) for 2years, then annually thereafter Percent and Number of Pre-InfusionPre-Infusion Patient Quarterly for Checklists received by Biogen IdecChecklists the first year, based on Confirmed Infusions biannually(every 6 months) for 2 years, then annually thereafter Number ofChecklists with a “No” Pre-Infusion Patient Quarterly for response toQuestions 1-4, number Checklists the first year, where infusionwithheld, number biannually where infusion was administered, (every 6number where prescriber was months) for 2 contacted, number whereprescriber years, then was unable to be contacted annually thereafterPercent and Number of TYSABRI ® Patient Quarterly for TYSABRI ® PatientStatus and Status Report and the first year, Re-AuthorizationQuestionnaire Reauthorization biannually completed comparedQuestionnaire data (every 6 to questionnaires sent months) for 2 years,then annually thereafter Number of TYSABRI ® patients TYSABRI ® PatientAnnually dosed outside of the Status Report and re-authorization periodQuestionnaire data, and Pre-Infusion Checklists Infusion Site compliancewith Pre-infusion Patient Quarterly for submission of completedChecklists the first year, Pre-infusion Patient Checklists biannually(every 6 months) for 2 years, then annually thereafter

The utility and ongoing need for the TOUCH Prescribing Program will beassessed 3 years after the re-introduction of TYSABRI®.

10.3.1 Audit Plan

Biogen Idec and Elan plan a detailed surveillance and audit process tomonitor TOUCH Prescribing Program compliance and the control anddispensing of the drug. The ongoing monitoring will include verificationof the completed Pre-Infusion Patient Checklists against data from theTOUCH Prescribing Program, verification of all distribution data toensure that TYSABRI® is only shipped to authorized infusion sites andcentral pharmacies, that patients are affiliated to authorized infusionsites, and that pre-infusion checklists are collected from infusionsites and in alignment with distribution data. In addition to ongoingmonitoring and reconciliation, Biogen Idec's Quality group will conductaudits at a select number of central pharmacies and infusion sites.Sites will be selected for audit based on a random sampling, taking intoaccount geographic region and infusion center type. The auditors willperform a physical inventory and review accountability of product at thesite. The auditors will also review certain TOUCH Prescribing Programrelated documentation. The auditors will report on noted discrepancies,such as, discrepancies in inventory levels or in TOUCH PrescribingProgram forms. Significant noncompliance will be included in establishedexception reports and reviewed by the TYSABRI® Compliance ReviewCommittee.

Routine compliance audits will be conducted at the single distributorand specialty pharmacies. As warranted, for cause audits will beconducted at a given site authorized in the TOUCH Prescribing Program.

Additional details of the monitoring and surveillance of the TOUCHprogram is contained in the Quality Plan.

10.3.2 De-Enrollment Process for Prescribers, Patients, Infusion Sites,Central Pharmacies, and Central Pharmacies for Non-Compliance

The Compliance Review Committee will review drug distribution,Pre-Infusion Patient Checklist, and TYSABRI® Patient Status Report andReauthorization Questionnaire compliance data to ensure all parties arecompliant. The committee will review exceptions, monthly and on a caseby case basis, and will make determinations as to whether any partiesshould be de-authorized in the TOUCH Prescribing Program due tosignificant non-compliance.

The system to handle non-compliance will be modeled after the BiogenIdec exception system used in the manufacturing, testing anddistribution of product. Quality approved procedures will addressidentification, notification, investigation, impact assessment,corrective and preventive action, escalation, tracking, monitoring,trending and documentation for exceptions. An exception will beclassified as major or minor based upon potential for significant impacton the objectives of the TOUCH Prescribing Program. An exceptionclassified as minor is not likely to impact the objectives of theRiskMAP, however, recurring minor exceptions may be classified as majorand may be indicative of a system issue. The Compliance Review Committeewill promptly review major exceptions. Quality will reside over theCommittee and have oversight in determination of corrective andpreventive actions taken to address the root cause of non-compliance. Inaddition, exceptions will be reviewed monthly by the Compliance ReviewCommittee, and quarterly by the TYSABRI® Management Review Committee, toassess suitability and effectiveness of procedures, processes andsystems to meet the objectives of the RiskMAP.

10.3.2.1 Prescriber De-Enrollment Process for Non-Compliance Significantnon-compliance with the requirements of the TOUCH Prescribing

Program may result in de-enrollment of the prescriber and forfeiture ofthe authorization to prescribe TYSABRI®. The Compliance Review Committeewill consider such cases on a case-by-case basis. Affected patients willbe directed to other authorized prescribers in the area; if this is notpossible, then the affected patients could potentially be de-authorizedas well.

10.3.2.2 Patient De-Enrollment Process for Non-Compliance

If a patient discontinues TYSABRI® as indicated on the TYSABRI® PatientStatus Report and Reauthorization Questionnaire, or by notifying BiogenIdec, Biogen Idec will follow the Patient Discontinuation processoutlined in Section 3.7. If a prescriber indicates that a patient islost to follow-up, Biogen Idec will contact that patient. If the patientplans to continue TYSABRI®-treatment, he/she will be instructed tocontact his or her new prescriber to complete a new Prescriber/PatientEnrollment form. If the form is not completed or Biogen Idec is unableto reach the patient, Biogen Idec will follow the PatientDiscontinuation process outlined in Section 3.7.

10.3.2.3 Infusion Site Process for Non-Compliance

An authorized infusion site will be informed that significantnon-compliance with the requirements of the TOUCH Prescribing Programmay result in de-enrollment of the infusion site and forfeiture of itsauthorization to administer TYSABRI®. Actionable non-compliance mayinclude actions such as dosing a non-authorized TYSABRI® patient, andnon-compliance with the requirement to complete and submit thePre-infusion Patient Checklist. The Compliance Review Committee willconsider such cases on a case-by-case basis. In such cases, Biogen Idecwill provide patients and prescribers with information about otherauthorized infusion sites in the area. Biogen Idec will notify centralpharmacies not to distributed TYSABRI® to de-authorized infused sites.

10.3.2.4 Central Pharmacies Process for Non-Compliance

Significant noncompliance with the requirements of the TOUCH PrescribingProgram may result in de-enrollment of the central pharmacy andforfeiture of the authorization to dispense TYSABRI®. Actionablenon-compliance may include dispensing TYSABRI® to non-authorizedinfusion sites. The Compliance Review Committee will consider such caseson a case-by-case basis. Biogen Idec will notify infusion sitesaffiliated with central pharmacies about the central pharmacyde-enrollment.

10.3.2.5 Specialty Pharmacies

Specialty Pharmacies are contractually obligated to comply with thecontrolled distribution system requirements. Noncompliance with theRiskMAP requirements may result in de-enrollment of the SpecialtyPharmacy and forfeiture of the authorization to dispense TYSABRI®.Actionable non-compliance may include dispensing TYSABRI® tonon-authorized infusion sites or not providing distribution data. TheCompliance Review Committee will consider such cases on a case-by-casebasis.

10.3.3 Assessment of Knowledge and Behaviors

Knowledge, attitude and behavior (KAB) surveys will be developed tosurvey, prescribers and infusion site nurses on their knowledge of thekey risk management messages of the TYSABRI® Risk Management Program andthe actions taken to minimize risk. The surveys will be developed andtested prior to implementation using standard psychometric methods forsurvey research (e.g., health literacy, content validity). A moredetailed description of the surveys will be provided to the FDA afterapproval.

10.3.3.1 Prescriber Survey

A sample of prescribers identified from the group of prescribers whohave authorized into the TOUCH prescribing program will be invited toparticipate in the prescriber survey. For generalizability of results, arandomly selected statistical sample of prescribers will be used.Prescriber samples will be mailed a KAB survey and asked to return it ina postage paid envelope. If the survey is not returned within 2 weeks, afollow-up reminder post card will be mailed. Prescribers who do notrespond within another two weeks will be telephoned and surveyed bydirect interview. Each selected sample will be unique, i.e., prescriberswill be interviewed only once in any given one year period.

10.3.3.2 Infusion Nurse Survey

A randomly selected, statistical sample of infusion nurses from the listof authorized infusion sites will be selected for the infusion nursesurvey. An attempt will be made to include nurses who administer thePre-Infusion Patient Checklist and infuse TYSABRI®. The selectedinfusion nurse will be mailed a KAB survey and asked to return it in apostage paid envelope. If the survey is not returned within 2 weeks, afollow-up reminder post card will be mailed. Infusion site nurses who donot respond within another two weeks will be telephoned and surveyed bydirect interview.

Example 2 Exemplary Computer Implementation

In an exemplary computer implementation, FIG. 9 is a block diagram ofcomputing devices and systems 400, 450. Computing device 400 is intendedto represent various forms of digital computers, such as laptops,desktops, workstations, personal digital assistants, servers, bladeservers, mainframes, and other appropriate computers. Computing device450 is intended to represent various forms of mobile devices, such aspersonal digital assistants, cellular telephones, smartphones, and othersimilar computing devices. The components shown here, their connectionsand relationships, and their functions, are meant to be exemplary only,and are not meant to limit implementations of the inventions describedand/or claimed in this document.

Computing device 400 includes a processor 402, memory 404, a storagedevice 406, a high-speed interface 408 connecting to memory 404 andhigh-speed expansion ports 410, and a low speed interface 412 connectingto low speed bus 414 and storage device 406. Each of the components 402,404, 406, 408, 410, and 412, are interconnected using various busses,and can be mounted on a common motherboard or in other manners asappropriate. The processor 402 can process instructions for executionwithin the computing device 400, including instructions stored in thememory 404 or on the storage device 406 to display graphical informationfor a GUI on an external input/output device, such as display 416coupled to high speed interface 408. In other implementations, multipleprocessors and/or multiple buses can be used, as appropriate, along withmultiple memories and types of memory. Also, multiple computing devices400 can be connected, with each device providing portions of thenecessary operations (e.g., as a server bank, a group of blade servers,or a multi-processor system).

The memory 404 stores information within the computing device 400. Inone implementation, the memory 404 is a computer-readable medium. In oneimplementation, the memory 404 is a volatile memory unit or units. Inanother implementation, the memory 404 is a non-volatile memory unit orunits.

The storage device 406 is capable of providing mass storage for thecomputing device 400. In one implementation, the storage device 406 is acomputer-readable medium. In various different implementations, thestorage device 406 can be a floppy disk device, a hard disk device, anoptical disk device, or a tape device, a flash memory or other similarsolid state memory device, or an array of devices, including devices ina storage area network or other configurations. In one implementation, acomputer program product is tangibly embodied in an information carrier.The computer program product contains instructions that, when executed,perform one or more methods, such as those described above. Theinformation carrier is a computer- or machine-readable medium, such asthe memory 404, the storage device 406, memory on processor 402, or apropagated signal.

The high speed controller 408 manages bandwidth-intensive operations forthe computing device 400, while the low speed controller 412 manageslower bandwidth-intensive operations. Such allocation of duties isexemplary only. In one implementation, the high-speed controller 408 iscoupled to memory 404, display 416 (e.g., through a graphics processoror accelerator), and to high-speed expansion ports 410, which can acceptvarious expansion cards (not shown). In the implementation, low-speedcontroller 412 is coupled to storage device 406 and low-speed expansionport 414. The low-speed expansion port, which can include variouscommunication ports (e.g., USB, Bluetooth, Ethernet, wireless Ethernet)can be coupled to one or more input/output devices, such as a keyboard,a pointing device, a scanner, or a networking device such as a switch orrouter, e.g., through a network adapter.

The computing device 400 can be implemented in a number of differentforms, as shown in the figure. For example, it can be implemented as astandard server 420, or multiple times in a group of such servers. Itcan also be implemented as part of a rack server system 424. Inaddition, it can be implemented in a personal computer such as a laptopcomputer 422. Alternatively, components from computing device 400 can becombined with other components in a mobile device (not shown), such asdevice 450. Each of such devices can contain one or more of computingdevice 400, 450, and an entire system can be made up of multiplecomputing devices 400, 450 communicating with each other.

Computing device 450 includes a processor 452, memory 464, one or moreinput/output device such as a display 454, a communication interface466, and a transceiver 468, among other components. The device 450 canalso be provided with a storage device, such as a microdrive or otherdevice, to provide additional storage. Each of the components 450, 452,464, 454, 466, and 468, are interconnected using various buses, andseveral of the components can be mounted on a common motherboard or inother manners as appropriate.

The processor 452 can process instructions for execution within thecomputing device 450, including instructions stored in the memory 464.The processor can also include separate analog and digital processors.The processor can provide, for example, for coordination of the othercomponents of the device 450, such as control of user interfaces,applications run by device 450, and wireless communication by device450.

Processor 452 can communicate with a user(s) through one or more controlinterface 458 and display interface 456 coupled to a display 454. Thedisplay 454 can be, for example, a TFT LCD display or an OLED display,or other appropriate display technology. The display interface 456 cancomprise appropriate circuitry for driving the display 454 to presentgraphical and other information to a user. The control interface 458 canreceive commands from a user and convert them for submission to theprocessor 452. In addition, an external interface 462 can be provide incommunication with processor 452, so as to enable near areacommunication of device 450 with other devices. External interface 462can provide, for example, for wired communication (e.g., via a dockingprocedure) or for wireless communication (e.g., via Bluetooth or othersuch technologies).

The memory 464 stores information within the computing device 450. Inone implementation, the memory 464 is a computer-readable medium. In oneimplementation, the memory 464 is a volatile memory unit or units. Inanother implementation, the memory 464 is a non-volatile memory unit orunits. Expansion memory 474 can also be provided and connected to device450 through expansion interface 472, which can include, for example, aSIMM card interface. Such expansion memory 474 can provide extra storagespace for device 450, or can also store applications or otherinformation for device 450. Specifically, expansion memory 474 caninclude instructions to carry out or supplement the processes describedabove, and can include secure information also. Thus, for example,expansion memory 474 can be provide as a security module for device 450,and can be programmed with instructions that permit secure use of device450. In addition, secure applications can be provided via the SIMMcards, along with additional information, such as placing identifyinginformation on the SIMM card in a non-hackable manner.

The memory can include for example, flash memory and/or MRAM memory, asdiscussed below. In one implementation, a computer program product istangibly embodied in an information carrier. The computer programproduct contains instructions that, when executed, perform one or moremethods, such as those described above. The information carrier is acomputer- or machine-readable medium, such as the memory 464, expansionmemory 474, memory on processor 452, or a propagated signal.

Device 450 can communicate wirelessly through communication interface466, which can include digital signal processing circuitry wherenecessary. Communication interface 466 can provide for communicationsunder various modes or protocols, such as GSM voice calls, SMS, EMS, orMMS messaging, CDMA, TDMA, PDC, WCDMA, CDMA2000, or GPRS, among others.Such communication can occur, for example, through radio-frequencytransceiver 468. In addition, short-range communication can occur, suchas using a Bluetooth, WiFi, or other such transceiver (not shown). Inaddition, GPS receiver module 470 can provide additional wireless datato device 450, which can be used as appropriate by applications runningon device 450.

Device 450 can also communication audibly using audio codec 460, whichcan receive spoken information from a user and convert it to usabledigital information. Audio codex 460 can likewise generate audible soundfor a user, such as through a speaker, e.g., in a handset of device 450.Such sound can include sound from voice telephone calls, can includerecorded sound (e.g., voice messages, music files, etc.) and can alsoinclude sound generated by applications operating on device 450.

The computing device 450 can be implemented in a number of differentforms, as shown in the figure. For example, it can be implemented as acellular telephone 480. It can also be implemented as part of asmartphone 482, personal digital assistant, or other similar mobiledevice.

Where appropriate, the systems and the functional operations describedin this specification can be implemented in digital electroniccircuitry, or in computer software, firmware, or hardware, including thestructural means disclosed in this specification and structuralequivalents thereof, or in combinations of them. The techniques can beimplemented as one or more computer program products, i.e., one or morecomputer programs tangibly embodied in an information carrier, e.g., ina machine readable storage device or in a propagated signal, forexecution by, or to control the operation of, data processing apparatus,e.g., a programmable processor, a computer, or multiple computers. Acomputer program (also known as a program, software, softwareapplication, or code) can be written in any form of programminglanguage, including compiled or interpreted languages, and it can bedeployed in any form, including as a stand alone program or as a module,component, subroutine, or other unit suitable for use in a computingenvironment. A computer program does not necessarily correspond to afile. A program can be stored in a portion of a file that holds otherprograms or data, in a single file dedicated to the program in question,or in multiple coordinated files (e.g., files that store one or moremodules, sub programs, or portions of code). A computer program can bedeployed to be executed on one computer or on multiple computers at onesite or distributed across multiple sites and interconnected by acommunication network.

The processes and logic flows described in this specification can beperformed by one or more programmable processors executing one or morecomputer programs to perform the described functions by operating oninput data and generating output. The processes and logic flows can alsobe performed by, and apparatus can be implemented as, special purposelogic circuitry, e.g., an FPGA (field programmable gate array) or anASIC (application specific integrated circuit).

Processors suitable for the execution of a computer program include, byway of example, both general and special purpose microprocessors, andany one or more processors of any kind of digital computer. Generally,the processor will receive instructions and data from a read only memoryor a random access memory or both. The essential elements of a computerare a processor for executing instructions and one or more memorydevices for storing instructions and data. Generally, a computer willalso include, or be operatively coupled to receive data from or transferdata to, or both, one or more mass storage devices for storing data,e.g., magnetic, magneto optical disks, or optical disks. Informationcarriers suitable for embodying computer program instructions and datainclude all forms of non volatile memory, including by way of examplesemiconductor memory devices, e.g., EPROM, EEPROM, and flash memorydevices; magnetic disks, e.g., internal hard disks or removable disks;magneto optical disks; and CD ROM and DVD-ROM disks. The processor andthe memory can be supplemented by, or incorporated in, special purposelogic circuitry.

To provide for interaction with a user, aspects of the describedtechniques can be implemented on a computer having a display device,e.g., a CRT (cathode ray tube) or LCD (liquid crystal display) monitor,for displaying information to the user and a keyboard and a pointingdevice, e.g., a mouse or a trackball, by which the user can provideinput to the computer. Other kinds of devices can be used to provide forinteraction with a user as well; for example, feedback provided to theuser can be any form of sensory feedback, e.g., visual feedback,auditory feedback, or tactile feedback; and input from the user can bereceived in any form, including acoustic, speech, or tactile input.

The techniques can be implemented in a computing system that includes aback-end component, e.g., as a data server, or that includes amiddleware component, e.g., an application server, or that includes afront-end component, e.g., a client computer having a graphical userinterface or a Web browser through which a user can interact with animplementation, or any combination of such back-end, middleware, orfront-end components. The components of the system can be interconnectedby any form or medium of digital data communication, e.g., acommunication network. Examples of communication networks include alocal area network (“LAN”) and a wide area network (“WAN”), e.g., theInternet.

The computing system can include clients and servers. A client andserver are generally remote from each other and typically interactthrough a communication network. The relationship of client and serverarises by virtue of computer programs running on the respectivecomputers and having a client-server relationship to each other.

Example 3 Forms

A number of embodiments of the invention have been described.Nevertheless, it will be understood that various modifications may bemade without departing from the spirit and scope of the invention.Accordingly, other embodiments are within the scope of the followingclaims.

What is claimed is:
 1. A method of providing an anti-VLA-4 antibody to apatient having relapsing MS comprising: (1) collecting patient andprescriber information; (2) reviewing said information or enrollmentform, entering information into a record system, and generating anauthorization; (3) communicating the authorization generated in (2) to atreatment site; and (4) conducting a treatment site review of a patientincluding i. determining if the treatment site has a currentauthorization for treatment of the patient; ii. confirming that thetreatment site does not have notice that the patient is no longerauthorized iii. providing the patient with information about the drug;iv. asking the patient if symptoms have worsened; v. asking the patientif he/she has a contraindicated medical condition; and vi. asking thepatient if he/she has taken a contraindicated medication; wherein ananswer of no to iv, v, and vi allows administration of the drug to thepatient and an answer of yes to one of iv, v, or vi requires prescriberoverride to administer the drug.
 2. The method of claim 1, furthercomprising: (5) upon expiration of an authorization, obtainingreauthorization for subsequent treatment prior to subsequent treatment,wherein reauthorization requires certification by the prescriber that(a) the patient still under his/her care; (b) the patient is alive; (c)the patient has had no unwanted side effect of the drug, nocontraindicated condition, or no contraindicated treatment that theprescriber has not already reported to the central administrator,provided that if the prescriber reauthorizes the patient must stillundergo the review in step (4) prior to receiving the drug.
 3. Themethod of claim 1, wherein prior to each shipment of the drug, adistributor of the drug obtains a shipment authorization from thecentral administrator.
 4. The method of claim 1, wherein said drug isshipped only to and administered only at authorized treatment sites. 5.The method of claim 1, wherein central pharmacies that dispense the drugto authorized treatment sites are enrolled in a tracking system.
 6. Themethod of claim 1, wherein the central administrator systematicallyfollows and actively solicits information on every patient that receivesthe drug regarding any adverse events.
 7. The method of claim 1, furthercomprising administering said anti-VLA4 antibody.
 8. The method of claim1, wherein said anti-VLA4 antibody is natalizumab.
 9. The method ofclaim 1, wherein the method is applied to at least 500 patients.
 10. Asystem configured to allow the practice of the method of claim 1comprising: instructions for carrying out the method of claim 1; a userinterface for inputting a query; and a processor for generating a queryresult.
 11. The system of claim 10, wherein the method carried out bythe system further comprises the following step: (5) upon expiration ofan authorization obtaining reauthorization for subsequent treatmentprior to subsequent treatment, wherein reauthorization requirescertification by the prescriber that (a) the patient still under his/hercare; (b) the patient is alive; (c) the patient has had no unwanted sideeffect of the drug, no contraindicated condition, or no contraindicatedtreatment that the prescriber has not already reported to the centraladministrator, provided that if the prescriber reauthorizes the patientmust still undergo the review in step (4) prior to receiving the drug.12. The system of claim 10, wherein the method carried out by the systemfurther requires that prior to each shipment of the drug, a distributorof the drug obtains a shipment authorization from the centraladministrator.
 13. The system of claim 10, wherein the method carriedout by the system further requires that said drug is shipped only to andadministered only at authorized treatment sites.
 14. The system of claim10, wherein the method carried out by the system further requires thatcentral pharmacies that dispense the drug to authorized treatment sitesare enrolled in a tracking system.
 15. The system of claim 10, whereinthe method carried out by the system further requires that the centraladministrator systematically follows and actively solicits informationon every patient that receives the drug regarding any adverse events.16. The system of claim 10, wherein said anti-VLA4 antibody isnatalizumab.
 17. The system of claim 10, wherein said method is appliedto at least 500 patients.
 18. A computer program product tangiblyembodied in an information carrier and comprising instructions that whenexecuted by a processor provide for performance of the method ofclaim
 1. 19. A database which includes a record all of the forms andinformation referred to in the method of claim 1 for a patient.
 20. Thedatabase of claim 19, having records for at least 100 patients.